“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

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

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

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

Aveva Solutions India LLP, Hyderabad vs. Income Tax Officer, Ward 8(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1170/HYD/2024[2021-22]Status: DisposedITAT Hyderabad19 Nov 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1170/Hyd/2024 Assessment Year – 2021-2022 Aveva Solutions India The Income Tax Officer, Llp, Hyderabad. Vs. Ward-8(1), Pin – 500 008. Hyderabad – 500 084. Pan Aayfa6913G (Appellant) (Respondent) Sri Percy Perdiwala, Advocate िनधा"रती "ारा /Assessee By: Shri Harsh Shah & Ca Karan Jain. राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Shri Harsh Shah and CA Karan JainFor Respondent: MS U Mini Chandran, CIT-DR

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 153(1)Section 153(4)Section 92C

ITA.No.1170/Hyd./2024 because allowing the said period of 30 days will again cross the limitation provided for passing the Final Assessment Order by 31.12.2023. Thus, the Learned Counsel for the Assessee has submitted that as per sub-sec.(2) of sec.144C, the Assessing Officer has to give 30 days ... limitation for completing the assessment is applicable as provided u/sec.144C(13) of the Act. Thus, the learned DR has submitted that once the Final Assessment Order is passed within the period of 30 days from the receipt of the DRP directions, then, it is well within the period of limitation

Mohhamed Abdul Aziz Khalid, Hyderabad vs. ACIT, (Int Taxn)-1, Hyderabad

In the result, appeal of the Assessee is dismissed

ITA 65/HYD/2023[2015-16]Status: DisposedITAT Hyderabad19 Nov 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.65/Hyd/2023 (िनधा"रण वष"/Assessment Year 2015-2016) Mohammed Abdul Aziz The Asst. Director Of Khalid, Hyderabad. Vs. Income Tax [Intl. Taxn- Pin – 500 036 1], Pan Awwpk9108R Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca P Murali Mohan Rao राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: CA P Murali Mohan RaoFor Respondent: MS U Mini Chandran, CIT-DR

Section 144CSection 147Section 156

Draft Assessment Order on merits. 3. On the other hand, the learned DR has submitted that this appeal is not against he Final Assessment Order passed by the Assessing Officer in pursuance to the directions of the DRP, but, since the assessee did not file the objections before ... therefore, the Assessing Officer passed the Final Assessment Order which is also challenged by the assessee before the learned CIT(A) which is pending adjudication. Thus, the learned DR has submitted that the appeal filed by the assessee is not maintainable as the assessment order passed by the Assessing Officer

Ramasamy Kandasamy, Karur vs. ITO, Ward-1, Karur

In the result, the appeal of the assessee is allowed

ITA 2023/CHNY/2025[2012-13]Status: DisposedITAT Chennai19 Nov 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No.2023/Chny/2025 िनधा"रण वष"/Assessment Year: 2012-13 V. Ramasamy Kandasamy, The Ito, No.4/76, Sf No.927, Sukkaliyur, Ward-1, Karur-639 003. Karur. [Pan: Ajgpk 4945 H]

For Appellant: Mr.H. Yeshwanth KumarFor Respondent: Ms.R. Anitha, Addl.CIT

Section 143(2)Section 143(3)Section 147Section 151

Supreme Court has granted an interim stay to the revenue against order of High Court that where Assessing Officer passed final assessment order without DIN, since there were по exceptional circumstances as mentioned in Circular No. 19/2019, dated 14-8- 2019, communication of impugned order manually without DIN, could

Lintas India Private Limited, Mumbai vs. DCIT, Circle 16(1), Mumbai

The appeal of the assessee is partly allowed for statistical purposes

ITA 5889/MUM/2024[2021-22]Status: DisposedITAT Mumbai19 Nov 2025AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2021-22 M/S. Lintas India Private Assessment Unit, Limited, Income Tax Department Or A Wing, 16Th Floor, Deputy Commissioner Of Parinee Crescenzo, Income Tax, Bandra-Kurla Complex, Circle 16(1), Bandra (East), 1) National Faceless Mumbai – 400 051 Assessment Centre (Nafac), Vs. Pan: Aaacl0124F Delhi 2)Aayakar Bhawan, Maharshi Karve Road, New Marine Lines, Churchgate, Mumbai – 400020 (Appellant) (Respondent) Present For: Assessee By : Shri Ajit Jain, Ld. A.R. Shri Karnik Kansara, Ld. A.R Ms. Neha Rai, Ld. A.R. Ms. Sakshi Chimanani, Ld. A.R. Revenue By : Shri Kiran Unavekar, Ld. Sr. D.R. Date Of Hearing : 22.08.2025 Date Of Pronouncement : 19.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 15.05.2023, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Dispute Resolution Panel-1) (In Short Ld. Commissioner) U/S 144C(5) Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2021-22. 2 M/S. Lintas India Private Limited

For Appellant: Shri Ajit Jain, Ld. A.RFor Respondent: Shri Kiran Unavekar, Ld. Sr. D.R

Section 144Section 144CSection 144C(5)Section 92C

Further, it is necessary to point out that for the year under consideration, only the assessee has a right to appeal against the final assessment order framed by the AO after incorporating the directions of the DRP and the Department does not have any such right of appeal. Under these

Shell India Markets Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(4), Mumbai

ITA 4828/MUM/2024[2020-21]Status: DisposedITAT Mumbai19 Nov 2025AY 2020-21

Bench: SHRI AMIT SHUKLA, JUDICIAL MEMBER\n&\nMS. PADMAVATHY S (Accountant Member)

Section 143(3)Section 144BSection 144C(1)Section 144C(13)Section 144C(5)Section 270ASection 40Section 92C

Hearing 21/08/2025 Date of Pronouncement 19/11/2025 आदेश / O R DER PER AMIT SHUKLA (J.M): This appeal by the assessee is directed against the final assessment order dated 31 July 2024 passed under section 143(3) read with section 144C(13) and section 144B of the Income ... assessee, the DRP, by directions dated 29 June 2024, substantially upheld the action of the TPO. Pursuant thereto, the Assessing Officer passed the final assessment order dated 31 July 2024 under section 143(3) read with section 144C(13) and section 144B, sustaining the transfer pricing adjustments as well

Dileep K Gupta, Delhi vs. DCIT CC-31, Delhi

In the result, the appeals of the assessee are allowed

ITA 153/DEL/2025[2021-22]Status: DisposedITAT Delhi19 Nov 2025AY 2021-22

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Amit Jain, CIT DR

Section 132Section 139Section 143(3)Section 153ASection 153D

seized documents perused by you & brought to the notice of undersigned. ITA Nos. 148 to 153/Del/2025 Dileep K. Gupta 3. Copies of the final assessment orders should be forwarded to this office immediately after passing the orders. Proposal for retention of seized material should also be forwarded to this office

Dileep K Gupta, Delhi vs. DCIT CC-31, Delhi

In the result, the appeals of the assessee are allowed

ITA 152/DEL/2025[2019-20]Status: DisposedITAT Delhi19 Nov 2025AY 2019-20

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Amit Jain, CIT DR

Section 132Section 139Section 143(3)Section 153ASection 153D

Dileep K Gupta, Delhi vs. DCIT CC-31, Delhi

In the result, the appeals of the assessee are allowed

ITA 151/DEL/2025[2018-19]Status: DisposedITAT Delhi19 Nov 2025AY 2018-19

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Amit Jain, CIT DR

Section 132Section 139Section 143(3)Section 153ASection 153D

Dileep K Gupta, Delhi vs. DCIT CC-31, Delhi

In the result, the appeals of the assessee are allowed

ITA 150/DEL/2025[2017-18]Status: DisposedITAT Delhi19 Nov 2025AY 2017-18

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Amit Jain, CIT DR

Section 132Section 139Section 143(3)Section 153ASection 153D

Dileep K Gupta, Delhi vs. DCIT, CC-31, Delhi

In the result, the appeals of the assessee are allowed

ITA 149/DEL/2025[2016-17]Status: DisposedITAT Delhi19 Nov 2025AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Amit Jain, CIT DR

Section 132Section 139Section 143(3)Section 153ASection 153D

Dileep K Gupta, Delhi vs. DCIT, CC-31, Delhi

In the result, the appeals of the assessee are allowed

ITA 148/DEL/2025[2015-16]Status: DisposedITAT Delhi19 Nov 2025AY 2015-16

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Amit Jain, CIT DR

Section 132Section 139Section 143(3)Section 153ASection 153D

Inteva Products Netherlands B.V., Netherlands vs. ACIT It Circle 2(1)(1), Delhi

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

ITA 1344/DEL/2025[2022-23]Status: DisposedITAT Delhi19 Nov 2025AY 2022-23

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Inteva Products Netherlands B.V. Vs. Acit, It Circle 2(1)(1), Siriusdreef 17, 2132, Wt, Hoofddorp, Delhi. Netherlands. (Pan :Aadci5208G) (Appellant) (Respondent) Assessee By : Shri Kshitij Bansal, Ca Revenue By : Shri Saroj Kumar Dubey, Cit Dr Date Of Hearing : 28.08.2025 Date Of Order : 19.11.2025 Order Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessee Is Directed Against The Assessment Order Dated 27.01.2025 Passed By The Acit, Circle Int. Tax 2(1)(1), Delhi Under Section 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2022-23Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :- “Ground 1 On The Facts & Circumstances Of The Case & In Law, The Assistant Commissioner Of Income-Tax, Circle International Tax - 2(1)(1), Delhi ('Ld.

For Appellant: Shri Kshitij Bansal, CAFor Respondent: Shri Saroj Kumar Dubey, CIT DR

Section 115ASection 143(3)Section 144C(5)Section 234BSection 270A

that the penalty proceedings be dropped.” 2. At the outset, ld. AR of the assessee submitted that the present appeal emanates from the final assessment order dated 27.01.2025 on the sole issue of taxability of business support services received by the assessee of Rs.8,28,34750/- as alleged

DCIT(It)-1(1)(1) Mumbai, Mumbai vs. Alibaba.Com Singapore E-Commerece Pvt. Ltd., Mumbai

In the result, appeals of the Revenue are dismissed

ITA 3125/MUM/2025[2014-15]Status: DisposedITAT Mumbai18 Nov 2025AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 9(1)Section 9(1)(vii)

interpreted. In support the AO relied upon the various decisions which have been discussed by him at pages 6 to 8 of his final assessment order. Apart from that, the AO has also made certain observations in para 37 & 38 which reads as under:- "In the instant case form

Sap India Private Limited, Bangalore vs. Jurisdictional Assessing Officer - Deputy Commissioner of Income Tax Circle 6(1)(1), Bangalore

The appeal of the assessee is allowed to the extent indicated above

ITA 1519/BANG/2024[2020-21]Status: DisposedITAT Bangalore17 Nov 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Soundararajan K, Jm

Section 143Section 144BSection 144C

appeal before us. The assessee is not pressing, ground No. [1] which is general, by ground No. [2] is contesting that the final assessment order passed is barred by limitation, general ground on transfer pricing adjustment of distribution segment as per ground No. 3 and other grounds on the transfer ... However, no relief was granted in respect of the adjustment pertaining to interest on overdue receivables. 09. Consequently, the final assessment order was passed by the learned Assessing Officer on 18 June 2020, determining the total income of the assessee at ₹11,716,843,086. The assessee is in appeal

Preity G Zinta, Mumbai vs. Income Tax Officer, Int Tax Ward 4(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 4199/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Nov 2025AY 2016-17

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2016-17 Preity G Zinta Income Tax Officer, Int Tax, 403 Parishram, Ward 4(3)(1), Smt. Nergish Dutt Road, Mumbai Bandra West Vs. Mumbai - 400050 Pan: Aaapz2650B (Appellant) (Respondent) Present For: Assessee : Shri. Dharan Gandhi & Ms. Vinita Nara, Advocates Revenue : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 21.08.2025 Date Of Pronouncement : 17.11.2025 O R D E R

For Appellant: Shri. Dharan Gandhi and Ms. Vinita Nara, AdvocatesFor Respondent: Shri Krishna Kumar, Sr. DR

Section 144C(5)Section 147Section 148Section 234ASection 271(1)(c)Section 271FSection 68

Mumbai, had no jurisdiction to passed the impugned order 4. The directions of Ld. DRP vide order dated 28.03.2025 and the final assessment order dated 29.04.2025 are barred by limitation and are therefore, bad in law 5. The Ld. AO has erred in the levying interest u/s. 234A, 234B, 234C ... penalty proceeding u/s 271F of the Act.” 3. This is the second round of litigation by the assessee before the Tribunal against the final assessment order passed pursuant to directions of ld. DRP u/s. 144C(5) r.w.s. 254 of the Act. Assessee is a non-resident individual working

Ador Welding Limited (Successor of Ador Fontech Limited), Mumbai vs. Deputy Commissioner of Income Tax, Circle 2(1)(1), Mumbai

In the result, we set-aside the order of the Ld

ITA 3338/MUM/2025[2021-22]Status: DisposedITAT Mumbai17 Nov 2025AY 2021-22

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2021-22 Ador Welding Limited Deputy Commissioner Of (Successor Of Ador Fontech Limited), Income Tax, Ador House, Vs. Circle-2(1)(1), 6 K Dubash Marg, Fort, Room No. 561, 5Th Floor, Mumbai-400001. Aayakar Bhavan, Pan : Aaaca9076B Maharshi Karve Road, Mumbai-400020. (Appellant) (Respondent)

For Appellant: Ms. Rupal KakuFor Respondent: Shri Surendra Mohan, Sr.DR

Section 142(1)Section 143(2)Section 143(3)Section 69A

from the GST Department. Astonishingly, the allegation against the assessee underwent a complete and contradictory shift between the Show Cause Notice and the final assessment order and also submitted that initially, in the Show Cause Notice dated 30-11- 2022, the AO alleged that the assessee had claimed bogus expenses ... returns. The allegation clearly implied that these were sham vendors, and the related expenses were fictitious. 8. It was submitted that in the final assessment order dated 13-12-2022, the AO abandoned this premise entirely and instead relying on GST Department data, alleged that these same four parties were

Rockwell Automation India Private Limited, Delhi vs. DCIT Circle-19(1), Delhi

Appeal is partly allowed for statistical purposes

ITA 3861/DEL/2024[2020-21]Status: DisposedITAT Delhi17 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalrockwell Automation India Deputy Commissioner Of Private Limited, Income Tax, Circle-19(1), Registered Address: 131, Vs. Delhi. Functional Industrial Are, Patparganj, Delhi-110092 Communication Address: 131, Functional Industrial Area, Patparganj, New Delhi. Pan-Aaccr3791A (Appellant) (Respondent) Assessee By Shri Ajit Jain, Ar Department By Shri Dharm Veer Singh, Cit-Dr Date Of Hearing 19.08.2025 Date Of Pronouncement 17.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Final Assessment Order Passed U/S 143(3) R.W.S 144C (13) Read With Section 144B Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 30.07.2024 For Assessment Year 2020-21. 2. Brief Facts Of The Case Ae That The Assessee Is A Company Engaged In The Business Of Manufacturing / Assembling Of Automation & Industrial Control Products / Systems. The Case Was Selected For Scrutiny & A Reference Was Made To The Tpo Due With Transactions With Ae’S. The Return Of Income Was Filed On Rockwell Automation India Private Limited Vs. Dcit 15.02.2021 Declaring Total Income At Rs.97,08,46,360/-. The Tpo Vide Its Order Dated 28.07.2023 Passed U/S 92Ca(3) Of The Act Has Proposed Adjustments Totaling To Rs. 26,12,44,668/-. Thereafter, The Ao Has Passed The Draft Assessment Order U/S 144C(1) Of The Act Dated 27.09.2023 Wherein The Ao Has Proposed The Additions Towards The Tp Adjustment As Per Tpo’S Order & Proposed To Assess The Total Income Of The Assessee At Rs.19,88,57,458/- & Further Proposed To Disallow Relief Claimed U/S 90/90A At Rs.1,04,60,287/-. Against The Draft Assessment Order, The Assessee Filed Objections Before The Drp.

Section 143(3)Section 144BSection 144C(1)Section 144C(10)Section 144C(13)Section 144C(8)Section 90Section 90ASection 92C

Date of Pronouncement 17.11.2025 O R D E R PER MANISH AGARWAL, AM: This appeal is filed by the assessee against the final assessment order passed u/s 143(3) r.w.s 144C (13) read with section 144B of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’) dated ... Business Support Services Segment – 1,69,10,011 (iii) Interest on outstanding receivables – 42,28,704 2.2 The AO have than passed the final assessment order on 30.07.2024 u/s 143(3) r.w.s. 144C(13) r.w.s. 1444B of the Act wherein after incorporating the adjustment referred by the TPO and further

Sempertrans India Private Limited, Roha vs. Income-Tax Officer, Panvel

In the result, appeal filed by the assessee is partly

ITA 1778/PUN/2024[AY 2020-21]Status: DisposedITAT Pune14 Nov 2025

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1778/Pun/2024

For Appellant: Shri Ajit Jain andFor Respondent: Shri Prakash L. Pathade

Section 144Section 144CSection 144C(8)Section 153Section 37(1)Section 92CSection 92D

under section 37(1). Accordingly, the directions of the Hon'ble DRP are bad in law and ought to be quashed. Consequently, the final assessment order dated 27 June 2024, is bad in law and ought to be quashed. Income Tax Officer, Vs. Panvel Circle, Panvel Respondent 2 ITA No.1778/PUN/2024 ... Private Limited 2. On the facts and circumstances of the case and in law, the Ld. AO has erred in not passing the final assessment order dated 27 June 2024 as per the directions of the Hon'ble DRP Panel as prescribed in section 144C (13), thereby rendering the assessment

My Home Industries Private Limited, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 289/HYD/2024[2018-2019]Status: DisposedITAT Hyderabad14 Nov 2025AY 2018-2019

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.289/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2018-19) My Home Industries Vs. Dy.Cit Private Limited, Hyderabad Circle 5(1) Pan: Aabcm9480C Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate A.V. Raghuram राज" व "ारा/Revenue By:: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 28/10/2025 घोषणा की तारीख/Pronouncement: 14/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By My Home Industries Private Limited, (“The Assessee”), Feeling Aggrieved By The Assessment Order Passed By The Learned Commissioner Of Income Tax (Appeals)-10, Hyderabad (“Ld. Cit(A)”) Dated 29.01.2024 For The A.Y 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Advocate A.V. RaghuramFor Respondent: : Dr. Narendra Kumar Naik, CIT (DR)

Section 143(2)Section 143(3)Section 144CSection 14ASection 92C

Home Industries P Ltd passed by the Ld. AO. Consequently, the Ld. AO passed the final assessment order under section 143(3) read with sections 144C(3) and 144B of the Act on 12.11.2021, making the same additions of Rs.37,49,66,519/- as proposed in the draft assessment order ... Thus, the total income of the assessee was assessed at Rs.157,73,97,449/-. 4. Aggrieved by the final assessment order passed by the Ld. AO, the assessee filed an appeal before the Ld. CIT(A). The Ld. CIT(A), after considering the submissions of the assessee and the remand

Deloitte Consulting India Projects Lp, Hyderabad vs. ADIT (Int Taxn)-1, Hyderabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1386/HYD/2024[2021-22]Status: HeardITAT Hyderabad14 Nov 2025AY 2021-22

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1386/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2021-22) M/S. Deloitte Consulting Vs. Asstt. Director Of Income India Projects Lp, Tax (Int.Taxation)-1 Hyderabad Hyderabad Pan:Aadcd1272B (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ketan K. Ved, Ca राज" व "ारा/Revenue By:: Smt. U Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 04/11/2025 घोषणा की तारीख/Pronouncement: 14/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri Ketan K. Ved, CAFor Respondent: : Smt. U Mini Chandran, CIT(DR)

Section 143(2)Section 143(3)Section 144C(1)Section 144C(13)Section 92C

vide its directions dated 09.09.2024, upheld the findings of the Ld. TPO. Accordingly, the Ld. AO passed a final assessment order under section 143(3) read with section 144C(13) of the Act on 22.10.2024 making the addition on account of TP adjustment of Rs.2,67,93,174/- determining ... total assessed income of the assessee at Rs.2,75,12,198/-. 5. Aggrieved with the final assessment order of the Ld. AO, the assessee is in appeal before us. At the outset, the Learned Authorized Representative (“Ld. AR”) submitted that the only dispute in appeal of the assessee relates