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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

Signode India Limited, Hyderabad vs. ACIT, Circle-3(1), Hyderabad

ITA 240/HYD/2023[2015-16]Status: DisposedITAT Hyderabad14 Nov 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri H. SrinivasuluFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(3)Section 144C(5)Section 32

Hearing : 25.08.2025 Date of Pronouncement : 14.11.2025 ORDER PER MANJUNATHA G. : These appeals have been filed by the assessee- company against (i) the Final Assessment Order dated 26.04.2021 passed by the A.O. under Section 143(3) r.w.s. 2 ITA.No.434/Hyd/2021 & ITA 240/Hyd/2023 M/s. Signode India Limited 144C(13) r.w.s. 144B ... vide Order dated 26.04.2021 passed u/sec.143(3) r.w.s.144C(13) r.w.s.144B of the Income Tax Act, 1961. 6. Aggrieved by the Final Assessment Order passed by the Assessing Officer, the assessee company is now, in appeal before the Tribunal. 13 ITA.No.434/Hyd/2021 & ITA 240/Hyd/2023 M/s. Signode India Limited

Signode India Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-3(1), Hyderabad

ITA 434/HYD/2021[2016-17]Status: DisposedITAT Hyderabad14 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri H. SrinivasuluFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(3)Section 144C(5)Section 32

Hearing : 25.08.2025 Date of Pronouncement : 14.11.2025 ORDER PER MANJUNATHA G. : These appeals have been filed by the assessee- company against (i) the Final Assessment Order dated 26.04.2021 passed by the A.O. under Section 143(3) r.w.s. 2 ITA.No.434/Hyd/2021 & ITA 240/Hyd/2023 M/s. Signode India Limited 144C(13) r.w.s. 144B ... vide Order dated 26.04.2021 passed u/sec.143(3) r.w.s.144C(13) r.w.s.144B of the Income Tax Act, 1961. 6. Aggrieved by the Final Assessment Order passed by the Assessing Officer, the assessee company is now, in appeal before the Tribunal. 13 ITA.No.434/Hyd/2021 & ITA 240/Hyd/2023 M/s. Signode India Limited

ACIT, Chennai vs. Updater Services Limited, Chennai

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

ITA 1616/CHNY/2025[2017]Status: DisposedITAT Chennai14 Nov 2025

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

For Appellant: Shri. K. Prasanna, C.AFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 115QSection 250Section 263Section 391Section 77A

aware of all documents were found irrelevant since the issues were never raised in the Section 142(1) notices. Furthermore, the final assessment order did not discuss the applicability of Sections 115QA, 56(2)(vii)(a), or the proportionate disallowance of interest. Therefore, it was concluded that the assessment

M/S. Updater Services Ltd., Chennai vs. DCIT, Central Circle-2(3), Chennai

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

ITA 1339/CHNY/2025[2017-18]Status: DisposedITAT Chennai14 Nov 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

For Appellant: Shri. K. Prasanna, C.AFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 115QSection 250Section 263Section 391Section 77A

aware of all documents were found irrelevant since the issues were never raised in the Section 142(1) notices. Furthermore, the final assessment order did not discuss the applicability of Sections 115QA, 56(2)(vii)(a), or the proportionate disallowance of interest. Therefore, it was concluded that the assessment

Rajnish Kasturchand Ostwal, Mumbai vs. Income Tax Officer, Int Tax Ward, 3(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1898/MUM/2025[2016-17]Status: DisposedITAT Mumbai14 Nov 2025AY 2016-17
Section 144C(13)Section 144C(5)Section 147Section 148Section 148ASection 69

Hearing 11/11/2025 Date of Pronouncement 14/11/2025 आदेश / ORDER PER AMIT SHUKLA (J.M): This appeal has been filed by the assessee against the final assessment order dated 24 January 2025 passed under section 147 read with section 144C(13) of the Income-tax Act, 1961 in pursuance of the directions issued

Fil India Business and Research Services Private Limited, Delhi vs. Assessment Unit, Income-Tax Department, Delhi

In the result, appeal of the assessee is partly allowed

ITA 3245/DEL/2024[2020-21]Status: DisposedITAT Delhi14 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2020-21] Fil India Business & Research Vs Assessment Unit Services Pvt. Ltd., Private Studio- Income Tax Ncra/Ac/Ps/00/010B, Ground Department, Delhi Floor, Worldmark 1, Asset Area 11, Aerocity, Hospitality District, Indira Gandhi International Airport, Delhi-110037. Pan-Aabcf1572C Appellant Respondent Appellant By Shri Ravi Sharma, Adv. & Shri Shitiz Bansal, Ar Respondent By Shri Dharm Veer Singh, Cit Dr Date Of Hearing 18.08.2025 Date Of Pronouncement 14.11.2025 Order

Section 143(3)Section 920Section 92C(3)

Date of Hearing 18.08.2025 Date of Pronouncement 14.11.2025 ORDER PER MANISH AGARWAL, AM : The present appeal is filed by the assessee against the final assessment order dated 27.06.2024 passed by Assessing Officer u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 [“the Act”] after incorporating ... passed u/s 143(1) of the Act which has not been challenged further by the Revenue, the disallowance made by AO in the final assessment order passed u/s 143(3) of INR 2,21,19,425/- is deleted. Accordingly, Ground of appeal Nos. 4 to 4.4 raised by the assessee

Pcl Foods Pvt. Ltd., Gurgaon vs. Addi CIT, National E- Assesment Centre, New Delhi

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

ITA 442/DEL/2021[2016-17]Status: DisposedITAT Delhi14 Nov 2025AY 2016-17

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh[Assessment Year: 2016-17] Pcl Foods Private Limited, Additional / Joint/ Unit No.-219, Plot No. 2, Deputy/Assistant Vardhman Crown Mall, Lsc, Vs Commissioner Of Income Sector 19, Dwarka, New Tax/ Income Tax Officer, Delhi-110075. National E-Assessment Centre, Delhi. Pan- Aahcp3493L Assessee Revenue

Section 143(3)Section 92C

442/Del/2021 PCL Foods Pvt. Ltd. ITA No.- 442/Del/2021 PCL Foods Pvt. Ltd. 6.1 The AO after receipt of the said OGE passed the final assessment order u/s 143(3) r.w.s. 144C(13) r.w.s. 143(3A) & 143(3B) of the Act on 22.02.2021 by making the following additions: I. On account ... foreign exchange gain / loss – export) for Rs. III. Default in deduction / collection - 27978 IV. Disallowance of capital expenditure - 17545 7. Against the above final assessment order, the assessee has filed an appeal before us. 7.1 Ground nos. 1 & 2 are reproduced as under: ““1. General Grounds 1. That

Madan Lal Tomar, Agra vs. ITO, Ward 2(1)(1), Agra

In the result, the appeal of the assessee is allowed

ITA 51/AGR/2025[2009-10]Status: DisposedITAT Agra13 Nov 2025AY 2009-10

Bench: Shri M. Balaganesh(Through Virtual Hearing) Sarvesh Devi Vs. Ito, (Legal Heir Of Late Madan Lal Ward-2(1)(1), Tomar, 51, Keshav Kunj, Agra Pratap Nagar, Agra, 282 001, Up (Appellant) (Respondent) Pan: Aaxpt3982D Assessee By : Shri Rajesh Malhotra, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 20/08/2025 Date Of Pronouncement 13/11/2025 O R D E R 1. The Appeal In Ita No. 51/Agr/2025 For Ay 2009-10, Arises Out Of The Order Of The Ld National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Ld. Nfac’, In Short] Dated 09.12.2024 Against The Order Of Assessment Passed U/S 147 R.W.S. 144 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 25.07.2019 By The Ito, Ward-4(2), Agra (Hereinafter Referred To As ‘Ld. Ao’).

For Appellant: Shri Rajesh Malhotra, CAFor Respondent: Shri Anil Kumar, Sr. DR
Section 143(2)Section 144Section 147Section 292B

provisions of Section 144C read with clause (b) of sub section 15. Moreover, it has been urged that in consequence, the final assessment order dated 31 October 2016 was beyond limitation in terms of Section 153(1) read with Section 153 (4). For the purposes of the present proceeding

Sarvesh Devi (Legal Heir of Late Madan Lal Tomar), Agra vs. ITO, Ward 2(1)(1), Agra

In the result, the appeal of the assessee is allowed

ITA 311/AGR/2025[2007-08]Status: DisposedITAT Agra13 Nov 2025AY 2007-08

Bench: Shri M. Balaganesh(Through Virtual Hearing) Sarvesh Devi (Legal Heir Vs. Income Tax Officer, Of Late Madan Lal Tomar), Ward-4(3)(1), 51, Keshavkunj Pratap Hathras Nagar, Agra (Appellant) (Respondent) Pan: Eshpd4540M Assessee By : Shri Rajesh Malhotra, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 18/08/2025 Date Of Pronouncement 13/11/2025

For Appellant: Shri Rajesh Malhotra, CAFor Respondent: Shri Anil Kumar, Sr. DR
Section 144Section 147Section 148Section 292B

provisions of Section 144C read with clause (b) of sub section 15. Moreover, it has been urged that in consequence, the final assessment order dated 31 October 2016 was beyond limitation in terms of Section 153(1) read with Section 153 (4). For the purposes of the present proceeding

Applexus Technologies Private Limited, Trivandrum vs. DCIT, Kottayam

ITA 955/COCH/2024[2021-2022]Status: DisposedITAT Cochin13 Nov 2025AY 2021-2022
For Appellant: Shri Reuben JosephFor Respondent: Shri Sanjit Kumar Das
Section 143(3)Section 144BSection 144CSection 144C(1)Section 144C(5)

order : 13.11.2025 O R D E R [ Per Rahul Chaudhary, Judicial Member: 1. The present appeal has been preferred by the Assessee challenging Final Assessment Order, dated 13/09/2024, passed by the Assessing Officer under Section 143(3) read with Section 144C read with Section 144B of the Income ... issued directions rejecting the contentions raised by the Assessee. Based on the directions issued by the DRP, the Assessing officer passed the Final Assessment Order, dated 13/09/2024, making transfer pricing addition of INR.3,95,53,825/-. Being aggrieved, the Assessee has preferred the present appeal raising grounds summarized in paragraph

M/S.Ibs Software Services P. Ltd, Trivandrum vs. The DCIT, Trivandrum

ITA 601/COCH/2017[2013-14]Status: DisposedITAT Cochin13 Nov 2025AY 2013-14

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajakannan, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144CSection 144C(5)Section 36(1)(iii)Section 36(1)(va)Section 92C

Rahul Chaudhary, Judicial Member: 1. The present appeal preferred by the Assessee is pertaining to Assessment Year 2013-2014 challenging Final Assessment Order, dated 18/09/2017, passed by the Assessing Officer under Section 143(3) read with Section 92CA read with Section 144C of the Income Tax Act, 1961 [hereinafter referred ... Order, dated 07/08/2017. DRP rejected the objections raised by the Assessee in relation to the aforesaid additions/disallowances. Accordingly, the Assessing Officer passed the Final Assessment Order, dated 18/09/2017, making. Inter alia, the following additions/disallowances: (a) Transfer pricing adjustment of INR.31,09,52,334/- (b) Loss on onerous contracts of INR.5

Bharti Mukesh Chandarana, Mumbai vs. Income Tax Officer (Int. Tax) Ward 2(1)(1), Mumbai

In the result, the ground No

ITA 4972/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Nov 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Bharti Mukesh Chandarana, Income Tax Officer Ward No. 64, Balasinor Society, S.V. Road, Vs 2(1)(1) Mumbai, Room No. 618, 6Th Floor, Kautilya Kandivali (West), Mumbai-400067, Maharashtra Bhawan, C-41 To C-43, G Block, [Pan No. Aacpc 4520F] Int Tax Ward, Bandra Kurla Complex, Bandra (East), Mumbai. Appellant / Assessee Respondent / Revenue

Section 132(4)Section 143(3)Section 144C(1)Section 144C(13)Section 147Section 148Section 151Section 153Section 153(2)Section 253

PAWAN SINGH, JUDICIAL MEMBER; 1. This second appeal under section 253 of Income Tax Act (Act) is filed by assessee against the final assessment order passed by assessing officer under section 143(3)/147 read with section 144C(13), passed in pursuance of direction of Dispute Resolution Panel (DRP) Mumbai ... assessing officer on all the legal as well as additions on merit. On receipt of order of DRP, the AO passed the final assessment order in pursuance of directions of DRP, which is challenged before this Tribunal by raising various grounds of appeal as recorded in para-1 of this

American Chemical Society, Usa vs. DCIT (International Tax), Circle 1(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1603/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Nov 2025AY 2022-23

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2022-23

For Respondent: Mr. Vishal Karla
Section 143(3)Section 144C(13)Section 9(1)(vi)

12/09/2025 Date of Hearing Date of pronouncement : 13/11/2025 ORDER PER OM PRAKASH KANT, AM This appeal by the assessee is directed against final assessment order dated 27.01.2025, passed by the Ld. Assistant/ Deputy Commissioner of Income-tax (International Taxation) – 1(1)(1), Mumbai (in short the Assessing Officer), pursuant

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 509/JPR/2025[2021-22]Status: DisposedITAT Jaipur12 Nov 2025AY 2021-22
For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

without passing any draft assessment order which is an essential requirement enumerated u/s 144C of the Act., The Section 144C requires that final assessment order against a Non-resident Assessee must be preceded by a draft assessment order if the Assessing Officer proposes to make any variation in income that

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 508/JPR/2025[2020-21]Status: DisposedITAT Jaipur12 Nov 2025AY 2020-21

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

without passing any draft assessment order which is an essential requirement enumerated u/s 144C of the Act., The Section 144C requires that final assessment order against a Non-resident Assessee must be preceded by a draft assessment order if the Assessing Officer proposes to make any variation in income that

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 507/JPR/2025[A.Y. 2018-19]Status: DisposedITAT Jaipur12 Nov 2025

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

without passing any draft assessment order which is an essential requirement enumerated u/s 144C of the Act., The Section 144C requires that final assessment order against a Non-resident Assessee must be preceded by a draft assessment order if the Assessing Officer proposes to make any variation in income that

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 506/JPR/2025[2016-17]Status: DisposedITAT Jaipur12 Nov 2025AY 2016-17

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

without passing any draft assessment order which is an essential requirement enumerated u/s 144C of the Act., The Section 144C requires that final assessment order against a Non-resident Assessee must be preceded by a draft assessment order if the Assessing Officer proposes to make any variation in income that

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 505/JPR/2025[2015-16]Status: DisposedITAT Jaipur12 Nov 2025AY 2015-16

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

without passing any draft assessment order which is an essential requirement enumerated u/s 144C of the Act., The Section 144C requires that final assessment order against a Non-resident Assessee must be preceded by a draft assessment order if the Assessing Officer proposes to make any variation in income that

Precision Camshafts Limited, Pune vs. DCIT Circle 1, Solapur

In the result, appeal of the assessee is partly allowed

ITA 2744/PUN/2024[2021-22]Status: DisposedITAT Pune12 Nov 2025AY 2021-22

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2744/Pun/2024 निर्धारण वषा / Assessment Year: 2021-22 Precision Camshafts Limited, V Assessment Unit, E-102/103, Akkalkot Road S Income Tax Department Midc, Solapur – 413006. (National Faceless Maharashtra. Assessment Center), Jurisdiction : Pne C(1), Range 63, Deputy Commissioner Of Income Tax („Dcit‟), Circle-1, Solapur. Pan: Aabcp1086B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil S Pathak - Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 21/08/2025 Date Of Pronouncement 12/11/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By Assessee Against The Assessment Order Under Section 143(3) R.W.S 144C(13) Read With Section 144B Of The Act, 1961 Dated 24.10.2024 For A.Y.2021-22 Emanating From Dispute Resolution Panel‟S Order Passed Under Section 144C(5) Of

Section 143(3)Section 144BSection 144C(1)Section 144C(5)Section 153Section 92B

only to final order and hence, the entire proceedings would have to be concluded within time limits prescribed. In the present case, the final assessment order has been passed beyond the time limit prescribed u/s. 153 accordingly, the said asst, order is null and void. B. Transfer Pricing Issues ... onwards, we will discuss each and every ground raised by the Assessee. Ground No.A : 8. This ground is regarding time limit to pass final assessment order u/s.153 of the Act. This ground was not pressed by the ld.AR. Accordingly, Ground No.A is dismissed as not pressed. Ground No.B : 9. This

Highradius Technologies Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle -2(1), Hyderabad

ITA 436/HYD/2024[2020-21]Status: HeardITAT Hyderabad12 Nov 2025AY 2020-21

Bench: Us:

Section 143(1)Section 143(3)Section 144B

which, vide its order dated 30.01.2024, substantially upheld the action of the TPO, except for minor corrections. 7. Thereafter, the AO vide his final assessment order passed under Section 143(3) r.w.s 144C(13) r.w.s 144B of the Act, dated 25/02/2024 (after taking the income of the assessee company determined