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“final assessment order”

Assessment ProceduresSection 144CSection 144C4,041 judgments

The decision most relied on for final assessment order is Parashuram Pottery Works Co. Ltd. v. ITO (106 ITR 1), cited in 486 judgments on BharatTax.

Leading authorities on final assessment order

Parashuram Pottery Works Co. Ltd. v. ITO
106 ITR 1 · 1977 · Supreme Court
486
citing judgments

The principle of finality dictates that stale issues should not be reactivated, and lapse of time brings repose to judicial and quasi-judicial controversies. A Commissioner cannot substitute their judgment for the Assessing Officer's unless the assessment order is legally erroneous, not merely less elaborate, thus limiting revisionary powers under Section 263.

Commissioner of Income Tax v. Roca Bathroom Products (P) ltd.
445 ITR 537 · 2022 · High Court
269
citing judgments

The time limit for the Assessing Officer to pass a final assessment order under Section 144C(13) following directions from the Dispute Resolution Panel is determined by the specific provisions of Section 153, particularly Section 153(2A).

CIT v. G.M. Knitting Industries (P.) Ltd.
376 ITR 456 · 2015 · Supreme Court
221
citing judgments

The requirement to file a certificate or form (e.g., Form 10CCB, 10-IC) along with the return of income for claiming a deduction (e.g., under sections 80-IB, 115BAA) is directory regarding its timing. Such a deduction is allowable if the requisite form is filed before the final order of assessment, as procedural requirements should not override substantive benefits.

Sultana Begum v. Prem Chand Jain
259 ITR 449 · 2003 · Supreme Court
147
citing judgments

Section 144C(4) uses a non-obstante clause to expedite the final assessment order, requiring the Assessing Officer to pass it immediately upon acceptance or lack of objection to the TPO's order, irrespective of broader time limits under Section 153.

Vijay Television (P.) Ltd. v. DRP
369 ITR 113 · 2014 · High Court
140
citing judgments

Passing a final assessment order under Section 143(3) directly, without first issuing a draft assessment order under Section 144C(1) for an eligible assessee, constitutes a fundamental jurisdictional defect. This defect cannot be cured by a subsequent corrigendum, especially if issued beyond the prescribed period of limitation.

ESPN Star Sports Mauritius S.N.C. ET Compagnie v. Union of India
388 ITR 383 · 2016 · High Court
71
citing judgments

Failure to issue a draft assessment order under Section 144C(1) makes the final assessment order illegal and beyond jurisdiction. Non-compliance with Dispute Resolution Panel (DRP) directions renders the final assessment order bad in law.

Travancore Diagnostics P. Ltd. v. ACIT
390 ITR 167 · 2017 · High Court
50
citing judgments

Failure to issue notice under section 143(2) before finalizing a reassessment order under section 147 is a fatal jurisdictional error, and this defect cannot be cured by invoking section 292BB of the Income-tax Act. Consequently, such a reassessment order is not sustainable in law.

Addl. CIT v. Mukur Corporation
111 ITR 312 · 1978 · High Court
49
citing judgments

When setting aside an assessment under Section 263(1) and directing a fresh assessment, the Commissioner need not record final conclusions or express final opinions on controversial points. It also interprets 'prejudicial to the interests of the Revenue' as meaning the assessment order is not in accordance with law, leading to the non-realization of lawful revenue.

Judgments citing final assessment order

Luminous Power Technologies Private Ltd., New Delhi vs. DCIT, Circle-13(1), Delhi

In the result Appeals of the Assessee in ITA Nos

ITA 1594/DEL/2022[2018-19]Status: DisposedITAT Delhi05 Dec 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Brajesh Kumar Singh

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 154Section 92C

YOGESH KUMAR, U.S. JM: The captioned appeals are filed by the assessee pertaining to Assessment Years 2017-18& 2018-19 challenging the Final Assessment Orders passed u/s 143(3) r.w. Section 144C(13) of the Income Tax Act, 1961 ('Act' for short) by Deputy Commissioner of Income Tax, Circle ... 04/03/2022. An order giving effect to the directions of TPO came to be passed u/s 144C of the Act on 21/04/2022. Further, a Final Assessment order came to be passed u/s 143(3) r.w. Section 144C(13) of the Act on 15/05/2022, wherein the Ld. A.O. assessed the total income

Luminous Power Technologies Private Ltd., New Delhi vs. DCIT, Circle-13(1), New Delhi

In the result Appeals of the Assessee in ITA Nos

ITA 1593/DEL/2022[2017-18]Status: DisposedITAT Delhi05 Dec 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Brajesh Kumar Singh

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 154Section 92C

YOGESH KUMAR, U.S. JM: The captioned appeals are filed by the assessee pertaining to Assessment Years 2017-18& 2018-19 challenging the Final Assessment Orders passed u/s 143(3) r.w. Section 144C(13) of the Income Tax Act, 1961 ('Act' for short) by Deputy Commissioner of Income Tax, Circle ... 04/03/2022. An order giving effect to the directions of TPO came to be passed u/s 144C of the Act on 21/04/2022. Further, a Final Assessment order came to be passed u/s 143(3) r.w. Section 144C(13) of the Act on 15/05/2022, wherein the Ld. A.O. assessed the total income

Kumar Gaurav Sharma, Currently Employed in Usa vs. Assessing Officer, Pune

In the result, the appeal of the assessee is partly allowed

ITA 598/PUN/2025[2019-20]Status: DisposedITAT Pune04 Dec 2025AY 2019-20
For Appellant: Department byFor Respondent: Date of hearing
Section 139(1)Section 143(1)Section 143(1)(a)Section 90

present case. In the present case, the returns were filed without FTC, however the same was filed before passing of the final assessment order. The filing of FTC in terms of the Rule 128 is only directory in nature. The rule is only for the implementation of the provisions ... petitioner on 02.02.2021. The respondent is directed to give due credit to the Kenya income of the petitioner and pass the final assessment order. Further, it is made clear that the impugned order is set aside only to the extent of disallowing of FTC claim made by the petitioner

DCIT, Swargate Pune vs. Cummins India Ltd, Pune

In the result, appeal of the assessee bearing ITA No

ITA 1256/PUN/2023[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Ms. Astha Chandra

Section 10ASection 115JSection 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 35

Revenue is in appeal vide ITA No. 1256/PUN/2023. Further, post selection of the assessee's case for complete scrutiny, a final assessment order u/s. 143(3) r.w.s.144C(13) of the Act has been framed on 30/06/2022 making various additions and adjustments against which assessee has preferred appeal before this Tribunal ... considering the submissions of the assessee, passed the order u/s.144C(5) of the Act on 18/05/2022 giving various directions. Ld.AO thereafter, passed a final assessment order on 30/06/2022 making various adjustments and instead of considering the income declared by the assessee in the final revised return, adopted the income

Cummins India Limited, Pune vs. Assistant Commissioner of Income-Tax, Circle - 1(1), Pune

In the result, appeal of the assessee bearing ITA No

ITA 632/PUN/2022[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Ms. Astha Chandra

For Appellant: Shri J.D. Mistri, Sr. Advocate &For Respondent: Shri Prakash L. Pathade, CIT-DR
Section 10ASection 13Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 80J

Revenue is in appeal vide ITA No. 1256/PUN/2023. Further, post selection of the assessee’s case for complete scrutiny, a final assessment order u/s. 143(3) r.w.s. 144C(13) of the Act has been framed on 30/06/2022 making various additions and adjustments against which assessee has preferred appeal before this ... submissions of the assessee, passed the order u/s. 144C(5) of the Act on 18/05/2022 giving various directions. Ld.AO thereafter, passed a final assessment order on 30/06/2022 making various adjustments and instead of considering the income declared by the assessee in the final revised return, adopted the income

Netcracker Technology Solutions (India) Private Limited, Hyderabad vs. DCIT., Circle - 5(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 730/HYD/2024[AY 2020-21]Status: DisposedITAT Hyderabad03 Dec 2025

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 92C(3)

तधरीख/ : 03.12.2025 Date of Pronouncement O R D E R PER MANJUNATHA G., A.M : This appeal filed by the assessee is against the final assessment order passed under Sections 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income-tax Act, 1961 (for short “the Act”), dated 06.06.2024, 2 NetCracker ... unjustified are liable to be deleted. VALIDITY OF THE ASSESSMENT ORDER 2 On the facts and in the circumstances of the case, the final assessment order passed by the Ld. AO under Section 143(3) read with Section 144C(13) read with Section 144B of the Act is barred

Brightcom Group Limited (Formerly Known As Lycos Internet Limited), Hyderabad vs. Asst. Commissioner of Income Tax, Circle-16(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 1862/HYD/2017[2013-14]Status: DisposedITAT Hyderabad03 Dec 2025AY 2013-14
Section 145Section 92BSection 92C

Date of Pronouncement O R D E R PER MANJUNATHA G., A.M : This appeal filed by the assessee is directed against the Final Assessment Order dated 30.10.2017 passed by the Assessing Officer (for short “the A.O.”) under Sections 143(3) r.w.s. 92CA(3) r.w.s. ITA 1862/Hyd/2017 Brightcom Group Limited 144C ... suitable adjustments to the TP additions. As per the directions of the DRP, the TPO suggested the additions to be made in the final assessment order to be passed by the A.O. The TPO upon receipt of a reference from the A.O. suggested an adjustment

International Flavours & Fragrances India Private Limited, Chennai vs. Principal Commissioner of Income Tax, Chennai

In the result, the appeal filed by the assessee is allowed

ITA 268/CHNY/2025[2017-18]Status: DisposedITAT Chennai02 Dec 2025AY 2017-18
For Appellant: Shri. Percy Pardiwalla, Senior AdvocateFor Respondent: Shri. Bipin C.N., C.I.T
Section 143(1)Section 143(2)Section 143(3)Section 147Section 263Section 801B

which included scrutiny of various international transactions undertaken by the assessee and eventually led to huge transfer pricing adjustment being made in the final assessment order. Thus, it stands established that the relevant material was examined and the matter was adjudicated upon after due application of mind, specifically the fact ... undertaken, which included scrutiny of various international transactions undertaken by the assessee and eventually made huge transfer pricing adjustment made in the final assessment order. Therefore, it is established that the Assessing Officer has examined the relevant material and the matter was adjudicated upon after due application of mind, specifically

Iqvia Ag, Switzerland vs. The Deputy Commissioner of Income Tax (Internaltional Taxation) - 2(2)(2), Mumbai

In the result, the appeal filed by the assessee is allowed in above terms

ITA 4549/MUM/2023[2021-22]Status: DisposedITAT Mumbai02 Dec 2025AY 2021-22

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 142(1)Section 143(2)Section 144C(5)Section 90(2)

revenue rejected the objection filed by the assessee. 4. In conformity with the directions issued by the DRP the assessing officer has passed final assessment order u/s 143(3) r.w.s 144C(13) of the Act on 15.02.2022 and assessed ITA No. 3359 & 4549/Mum/2023 IQVIA AG the aforesaid subscription fees

Iqvia Ag, Switzerland vs. The Income Tax Officer (International Taxation) - 2(2)(1), Mumbai

In the result, the appeal filed by the assessee is allowed in above terms

ITA 3359/MUM/2023[2020-21]Status: DisposedITAT Mumbai02 Dec 2025AY 2020-21

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 142(1)Section 143(2)Section 144C(5)Section 90(2)

revenue rejected the objection filed by the assessee. 4. In conformity with the directions issued by the DRP the assessing officer has passed final assessment order u/s 143(3) r.w.s 144C(13) of the Act on 15.02.2022 and assessed ITA No. 3359 & 4549/Mum/2023 IQVIA AG the aforesaid subscription fees

Fuji Electric India Private Limited, Chennai vs. Deputy Commissioner of Income Tax, Corporate Circle 1(1), Chennai

In the result the appeal of the Assessee is partly allowed for statistical purposes

ITA 701/CHNY/2025[2020-21]Status: DisposedITAT Chennai01 Dec 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. Siddhesh Chaugula, C.AFor Respondent: Shri. A R V Sreenivasan, C.I.T
Section 92C

both the additions made by the AO on the premise that year end provisions without payment of TDS are not allowable. Against the final assessment order, now the Assessee is agitating both the aforesaid issues before us and the Ld.AR submitted as under: “Background of Business Operations • The Appellant ... Ground no.5: Erroneous computation of book profits. 15.1 The Ld.AR contended that the Assessee had book losses but the AO while passing the Final Assessment Order in the Computation Sheet has erroneously computed book profit of Rs.18,16,055/-. We find that the issue has emerged post DRP directions

Matrix Clothing Private Limited, Gurgaon vs. ACIT-CC-18, Delhi

In the result, the appeal of the assessee is partly allowed

ITA 3805/DEL/2024[2020-21]Status: DisposedITAT Delhi01 Dec 2025AY 2020-21

Bench: Shri M. Balaganesh & Shri Vimal Kumarmatrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B Assessee By : Ms. Kavita Jha, Sr. Adv Shri Himanshu Agarwal, Adv Shri Akash Shukla, Adv Revenue By: Shri Chetan P. S. Rao, Cit Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 01/12/2025 Matrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B

For Appellant: Ms. Kavita Jha, Sr. AdvFor Respondent: Shri Chetan P. S. Rao, CIT DR
Section 133(6)Section 143(3)Section 144C(5)Section 92C

have got it reimbursed from its AE. This addition stood upheld by the ld DRP and accordingly the same was adopted in final assessment order. 5. At the outset, we find that ld TPO had proceeded on the wrong presumption that assessee had not recovered any amount on account ... proposed a transfer pricing adjustment of ₹20,66,415/- in the draft assessment order which got reduced to ₹15,42,924/- in the final assessment order passed pursuant to the directions of ld DRP. It is pertinent to note that rate adopted by the assessee is on the basis

Matrix Clothing Private Limited, Gurgaon vs. ACIT, Central Circle-18, Delhi

In the result, the appeal of the assessee is partly allowed

ITA 760/DEL/2022[2017-18]Status: DisposedITAT Delhi01 Dec 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumarmatrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B Assessee By : Ms. Kavita Jha, Sr. Adv Shri Himanshu Agarwal, Adv Shri Akash Shukla, Adv Revenue By: Shri Chetan P. S. Rao, Cit Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 01/12/2025 Matrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B

For Appellant: Ms. Kavita Jha, Sr. AdvFor Respondent: Shri Chetan P. S. Rao, CIT DR
Section 133(6)Section 143(3)Section 144C(5)Section 92C

have got it reimbursed from its AE. This addition stood upheld by the ld DRP and accordingly the same was adopted in final assessment order. 5. At the outset, we find that ld TPO had proceeded on the wrong presumption that assessee had not recovered any amount on account ... proposed a transfer pricing adjustment of ₹20,66,415/- in the draft assessment order which got reduced to ₹15,42,924/- in the final assessment order passed pursuant to the directions of ld DRP. It is pertinent to note that rate adopted by the assessee is on the basis

Brijesh Chandwani, Hyderabad vs. DCIT., Circle -6(1), Hyderabad

In the result, appeal of the assessee for the assessment year 2020-2021 is allowed for statistical purposes

ITA 1528/HYD/2025[2020-2021]Status: DisposedITAT Hyderabad28 Nov 2025AY 2020-2021

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1527 & 1528/Hyd/2025 Assessment Years – 2016-2017 & 2020-2021 Brijesh Chandwani The Dcit, Circle-6(1), Vs. Hyderabad – 500 034 Hyderabad. Pan Adkpc1537H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा /Revenue By: Sri Ranjan Agrawala, Sr. Ar

For Appellant: CA Pawan Kumar ChakrapaniFor Respondent: Sri Ranjan Agrawala, Sr. AR
Section 133ASection 143(1)(a)Section 143(3)Section 147Section 148Section 148ASection 234A

u/sec.148 of the Act dated 30.07.2022 by obtaining prior approval from the Principal Commissioner of Income Tax-1, Hyderabad dated 27.07.2022 and consequential final assessment order dated 02.03.2024 passed by the Assessing Officer u/sec.147 r.w.s.144C(13) of the Act is illegal, void abinitio and thus, we quash the final assessment ... applicable from 01.04.2021 onwards. Therefore, we quash the notice issued u/sec.148 of the Act dated 01.04.2021 and 27.07.2022 and consequent Final Assessment Order dated 13.03.2024 passed by the Assessing Officer u/sec.147 r.w.s.144C(13) of the Income Tax Act, 1961. Accordingly, the grounds raised by the assessee for the assessment year

Brijesh Chandwani, Hyderabad vs. DCIT., Circle -6(1), Hyderabad

The appeal of the Assessee is allowed on this ground alone

ITA 1527/HYD/2025[2016-2017]Status: DisposedITAT Hyderabad28 Nov 2025AY 2016-2017
For Appellant: CA Pawan Kumar ChakrapaniFor Respondent: Sri Ranjan Agrawala, Sr. AR
Section 133ASection 143(1)(a)Section 143(3)Section 147Section 148Section 148ASection 234A

u/sec.148 of the Act dated 30.07.2022 by obtaining prior approval from the Principal Commissioner of Income Tax-1, Hyderabad dated 27.07.2022 and consequential final assessment order dated 02.03.2024 passed by the Assessing Officer u/sec.147 r.w.s.144C(13) of the Act is illegal, void abinitio and thus, we quash the final assessment ... applicable from 01.04.2021 onwards. Therefore, we quash the notice issued u/sec.148 of the Act dated 01.04.2021 and 27.07.2022 and consequent Final Assessment Order dated 13.03.2024 passed by the Assessing Officer u/sec.147 r.w.s.144C(13) of the Income Tax Act, 1961. Accordingly, the grounds raised by the assessee for the assessment year

Vinod Ojha, Hyderabad vs. Income Tax Officer, Ward-5(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1231/HYD/2024[2016-17]Status: DisposedITAT Hyderabad28 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1231/Hyd/2024 (िनधा"रण वष"/Assessment Year 2016-2017) Vinod Ojha, The Income Tax Officer, Ward-5(1), Hyderabad-500012. Vs. Hyderabad – 500 057. Telangana. Telangana. Pan Aahpo3171F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Kumar Pal Tated राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr

For Appellant: CA Kumar Pal TatedFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 139(1)Section 144Section 147Section 148Section 149

dated 30.07.2022 by obtaining prior approval from the 34 ITA.No.1231/Hyd./2024 Principal Commissioner of Income Tax-1, Hyderabad dated 27.07.2022 and consequential final assessment order dated 02.03.2024 passed by the Assessing Officer u/sec.147 r.w.s.144C(13) of the Act is illegal, void abinitio and thus, we quash the final assessment

Microsoft Research Lab India Private Limited, Bengaluru vs. Deputy Commissioner of Income-Tax, Circle 4(1)(1), Bengaluru

In the result, the appeal is set aside for doing it denovo

ITA 1842/BANG/2024[AY 2017-18]Status: DisposedITAT Bangalore28 Nov 2025

Bench: Ms. Padmavathy S. & Shri Rahul Chaudhary

For Appellant: Sri Nageshwar RaoFor Respondent: Dr. Divya K.J
Section 143(3)Section 144BSection 144CSection 144C(2)Section 144C(3)Section 153Section 153BSection 250

Income Tax Act, 1961 [hereinafter referred to as ‘the Act’] whereby the Ld. CIT(A) had disposed off the appeal against the Final Assessment Order, dated 23/04/2021, passed under Section 143(3) read with Section 144B of the Act for the Assessment Year 2017-2018. 2. By way of Ground ... raised in the present appeal, the Assessee had challenged the validity of the Final Assessment Order, dated IT(TP)A No.1842/Bang/2024 Assessment Year 2017-2018 30/03/2015. Ground No. 5 raised by the Assessee reads as under: “Impugned order failed in not holding the Assessment order dated 23.4.2021 as invalid, null

Marvell India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-4(1)(1), Bengaluru

In the result, the appeal filed by the assessee is partly allowed

ITA 1608/BANG/2024[2020-21]Status: DisposedITAT Bangalore28 Nov 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Rahul Chaudharym/S. Marvell India Private Limited 10Th Floor, Tower D & E Global Technology Park, Marathahalli Outer Ring Road Devarabeesanahalli Village Varthurhobli Bangalore 560 103 ………. Appellant [Pan: Aaecm5559R]

For Appellant: Sri Chavali NarayanFor Respondent: Sri Muthu Shankar
Section 143(3)Section 144C(1)Section 144C(13)Section 200ASection 234ASection 234BSection 234CSection 270ASection 274Section 28

Rahul Chaudhary, Judicial Member: 1. The present appeal preferred by the Assessee is directed against the Final Assessment Order, dated 27/06/2024, passed by the Deputy Commissioner of Income Tax, Circle-4(1)(1), Bangalore under Section 143(3) read with Section 144C(13) of the Income Tax Act, 1961 [hereinafter ... agreed with the Assessing Officer and declined to grant any relief to the Assessee. Therefore, the Assessing Officer concluded the assessment and passed Final Assessment Order, dated 27/06/2024, making the following additions/disallowances: (a) Disallowance of Depreciation claimed on Goodwill amounting to INR.3,08,21,235/- (b) Addition on account

Mercedes-Benz Research and Development India Private Limited, Bengaluru vs. Assistant Commissioner of Income-Tax, Special Range-4, Bangalore

In the result, appeal of the assessee and the appeal of the revenue are partly allowed

ITA 972/BANG/2023[2017-18]Status: DisposedITAT Bangalore28 Nov 2025AY 2017-18

Bench: Ms. Padmavathy S. & Shri Keshav Dubeyassessmentyear:2017-18

For Appellant: Sri Kamal Sawhney, A.RFor Respondent: Dr. Diyva K.J., D.R
Section 250Section 92C

tune of Rs.66,16,19,971/- and in Engineering Design Services (EDS) amounting to Rs.50,99,54,357/. The AO passed the final assessment order incorporating the Transfer Pricing adjustments. The assessee preferred further appeal against the final assessment order. The ld. CIT(A) after considering the various submissions

Devindra Singh, Jhajjar vs. DCIT, Int. Tax, Gurgaon

In the result, impugned assessment order is quashed being without jurisdiction and appeal of the assessee is allowed

ITA 4715/DEL/2025[2015-16]Status: DisposedITAT Delhi28 Nov 2025AY 2015-16

Bench: Shri Vikas Awasthy& Shri M. Balaganeshआअसं.4715/िद"ी/2025(िन.व. 2015-16) Devindra Singh, Viilage Naya Gaon, Bahadurgarh, Jhajjar, Haryana 124507 ...... अपीलाथ"/Appellant Pan No: Akppg-1164-L बनाम Vs. Deputy/Assistant Commissioner Of Income Tax, ....."ितवादी/Respondent International Taxation, Gurgaon, Haryana

For Appellant: S/Shri Pranshu Singhal, Chartered Accountants &For Respondent: Shri M.S Nethrapal, CIT-DR
Section 143(1)Section 144CSection 147Section 148Section 148ASection 68

assessee with respect to cash deposits to the extent of Rs.17,11,500/-. Consequent, to the direction of DRP, the AO passed the final assessment order dated 24.01.2025 accepting that inadvertently the amount deposited in the bank was taken into account twice while passing the order u/s. 148A