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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

The Milestone Aviation Asset Holding Group No.25 Ltd., Ireland vs. ACIT Int. Tax. Circle 3(1)(1) New Delhi, New Delhi

In the result, this issue is decided in favour of the appellant assessees and against the Revenue

ITA 1351/DEL/2025[2022-2023]Status: DisposedITAT Delhi31 Oct 2025AY 2022-2023

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.1350/Del./2025, A.Y. 2022-23 Vertical Aviation No. 1 Ltd., Assistant Commissioner Of Dolmen House, 3Rd Floor, Income Tax, 4 Earlsfort Terrace, Vs. Circle Int. Tax. - 3(1)(1), Dublin 2, Ireland Do2E024 Civic Centre, Minto Road, Pan: Aafcv8726N New Delhi-110002 (Appellant) (Respondent) Ita No.1351/Del./2025, A.Y. 2022-23 The Milestone Aviation Assistant Commissioner Of Asset Holding Group No. 25 Income Tax, Ltd., Vs. Circle Int. Tax. - 3(1)(1), Dolmen House, 3Rd Floor, Civic Centre, Minto Road, 4 Earlsfort Terrace, New Delhi-10002 Dublin 2, Ireland D02E024 Pan: Aahct8009N (Appellant) (Respondent) Both Appellant By Sh. Sachit Jolly, Sr. Advocate Ms. Rashi Khanna, Advocate Ms. Viyushti Rawat, Advocate (Vc) Sh. Devansh Jain, Advocate Ms. Disha Jham, Advocate Sh. Soham Dua, Advocate, Sh. Hardeep Singh, Advocate & Sh. A. S. Bajpai, Advocate Both Respondent By Shri Indruj S. Rai, Spl. Counsel, Sh. Sanjeev Menon, Jr. Sc, Sh. Rahul Singh, Jr. Sc, Sh. Gaurav Kumar, Adv. Ms. Rini Handa, Jcit (Intl. Tax) Date Of Hearing 12/09/2025 Date Of Pronouncement 31/10/2025 Common & Identical.

Section 143(3)Section 153Section 194LSection 9(1)(vii)

rentals by the Indian lessee to the assessee (as lessor) were taxable in India under Article 11 of India-Ireland DTAA. Dissatisfied with final assessment orders, these appeals are here. 5. Sh. Sachit Jolly, Sr. Advocate representing both assessees at the outset made a statement at Bar that the assessees ... leased out to Inter Globe Aviation Ltd. (Indigo) an Indian company for leasing of aircraft AIRBUS. It was further submitted that the final assessment orders were passed along with other cases who had leased aircrafts to Inter Globe Aviation Ltd. (Indigo) and facts mentioned in those cases had been reiterated

Vertical Aviation No. 1 Limited, Ireland vs. ACIT Int. Tax. Circle 3(1)(1) New Delhi, New Delhi

In the result, this issue is decided in favour of the appellant assessees and against the Revenue

ITA 1350/DEL/2025[2022-2023]Status: DisposedITAT Delhi31 Oct 2025AY 2022-2023

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.1350/Del./2025, A.Y. 2022-23 Vertical Aviation No. 1 Ltd., Assistant Commissioner Of Dolmen House, 3Rd Floor, Income Tax, 4 Earlsfort Terrace, Vs. Circle Int. Tax. - 3(1)(1), Dublin 2, Ireland Do2E024 Civic Centre, Minto Road, Pan: Aafcv8726N New Delhi-110002 (Appellant) (Respondent) Ita No.1351/Del./2025, A.Y. 2022-23 The Milestone Aviation Assistant Commissioner Of Asset Holding Group No. 25 Income Tax, Ltd., Vs. Circle Int. Tax. - 3(1)(1), Dolmen House, 3Rd Floor, Civic Centre, Minto Road, 4 Earlsfort Terrace, New Delhi-10002 Dublin 2, Ireland D02E024 Pan: Aahct8009N (Appellant) (Respondent) Both Appellant By Sh. Sachit Jolly, Sr. Advocate Ms. Rashi Khanna, Advocate Ms. Viyushti Rawat, Advocate (Vc) Sh. Devansh Jain, Advocate Ms. Disha Jham, Advocate Sh. Soham Dua, Advocate, Sh. Hardeep Singh, Advocate & Sh. A. S. Bajpai, Advocate Both Respondent By Shri Indruj S. Rai, Spl. Counsel, Sh. Sanjeev Menon, Jr. Sc, Sh. Rahul Singh, Jr. Sc, Sh. Gaurav Kumar, Adv. Ms. Rini Handa, Jcit (Intl. Tax) Date Of Hearing 12/09/2025 Date Of Pronouncement 31/10/2025 Common & Identical.

Section 143(3)Section 153Section 194LSection 9(1)(vii)

rentals by the Indian lessee to the assessee (as lessor) were taxable in India under Article 11 of India-Ireland DTAA. Dissatisfied with final assessment orders, these appeals are here. 5. Sh. Sachit Jolly, Sr. Advocate representing both assessees at the outset made a statement at Bar that the assessees ... leased out to Inter Globe Aviation Ltd. (Indigo) an Indian company for leasing of aircraft AIRBUS. It was further submitted that the final assessment orders were passed along with other cases who had leased aircrafts to Inter Globe Aviation Ltd. (Indigo) and facts mentioned in those cases had been reiterated

Miteshkumar Dayaljibhai Pabari, Bhatiya vs. Assistant Commissioner/ Deputy Commissioner, Rajkot

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

ITA 420/RJT/2025[2020-21]Status: DisposedITAT Rajkot30 Oct 2025AY 2020-21

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 420 /Rjt/2025 (िनधा"रण वष"/Assessment Year: (2020-21) Miteshkumar Dayaljibhai Pabari Assistant Commissioner/Deputy Commissioner, International C/O Dayaljibhai Pabari, Shreeji Catlery Vs. Taxation Rajkot, Stores, Main Bajar, Bhatiya, Devbhoomi Dwarka, Room No. 312, Income Tax Office, Amruta Estate Building, Near Girnar Dwarka-361315(Gujarat) Cinema, M.G. Road, Rajkot – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bctpp7290M (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mahesh Paun, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 151Section 274Section 69

following address: The Secretary, Dispute Resolution Panel-2, World Trade Center, Cufffe Parade, Colaba, Mumbai- 400005, failing which the final assessment order u/s 147 r.w.s.144C(3)/144C(13) of the Income-tax Act shall be passed assessing the total income of the assessee as proposed here-in-above. 8.Aggrived ... 420/RJT/2025 MITESHKUMAR PABARI Page 7 of 12 ITA 420/RJT/2025 MITESHKUMAR PABARI 9. Then after, the assessing officer framed the final assessment order u/s. 147 r.w.s. 144C(3) of the Act dated 26.05.2025, stating that the assessee fails to submit the proof of payment of purchase consideration of the impugned property

ACIT(It)-1.2.2 Mumbai, Bkc, Mumbai vs. Bcd Travel Asia Pacific Pte Ltd, Singapore

Accordingly, the cross-objections are rendered infructuous and are dismissed as such

ITA 4849/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Oct 2025AY 2020-21

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

Section 143(3)Section 234DSection 9(1)(vi)

cross- objections for all years, raising the following grounds which are common across the years under appeal: Ground No. 1: That the final assessment order dated 10 November 2021, passed u/s. 143(3) r.w.s. 144C(3) of the Act, is barred by limitation, void-ab-initio

ACIT(It)-1(2)(2), Mumbai, Bkc vs. Bcd Travel Asia Pacific Pte Limited, Singapore

ITA 4704/MUM/2025[2019-20]Status: DisposedITAT Mumbai30 Oct 2025AY 2019-20
Section 143(3)Section 234DSection 9(1)(vi)

cross- objections for all years, raising the following grounds which are common across the years under appeal: Ground No. 1: That the final assessment order dated 10 November 2021, passed u/s.143(3) r.w.s.144C(3) of the Act, is barred by limitation, void-ab-initio, bad in law and liable

ACIT(It)-1.2.2, Bkc, Mumbai vs. Bcd Travel Asia Pacific Pte Limited, Singapore

Accordingly, the cross-objections are rendered infructuous and are dismissed as such

ITA 4572/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Oct 2025AY 2017-18

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

Section 143(3)Section 234DSection 9(1)(vi)

cross- objections for all years, raising the following grounds which are common across the years under appeal: Ground No. 1: That the final assessment order dated 10 November 2021, passed u/s. 143(3) r.w.s. 144C(3) of the Act, is barred by limitation, void-ab-initio

ACIT(It)-1.2.2, Bkc, Mumbai vs. Bcd Travel Services Bv, Netherland

Accordingly, the cross-objections are rendered infructuous and are dismissed as such

ITA 4571/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Oct 2025AY 2020-21

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

Section 143(3)Section 234DSection 9(1)(vi)

cross- objections for all years, raising the following grounds which are common across the years under appeal: Ground No. 1: That the final assessment order dated 10 November 2021, passed u/s. 143(3) r.w.s. 144C(3) of the Act, is barred by limitation, void-ab-initio

ACIT(It)-1.2.2, Bkc, Mumbai vs. Bcd Travel Services Bv, Netherlands

Accordingly, the cross-objections are rendered infructuous and are dismissed as such

ITA 4570/MUM/2025[2019-20]Status: DisposedITAT Mumbai30 Oct 2025AY 2019-20

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

Section 143(3)Section 234DSection 9(1)(vi)

cross- objections for all years, raising the following grounds which are common across the years under appeal: Ground No. 1: That the final assessment order dated 10 November 2021, passed u/s. 143(3) r.w.s. 144C(3) of the Act, is barred by limitation, void-ab-initio

ACIT(It)-1.2.2, Mumbai, Bkc vs. Bcd Travel Asia Pacific Pte Limited, Singapore

Accordingly, the cross-objections are rendered infructuous and are dismissed as such

ITA 4569/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Oct 2025AY 2018-19

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

Section 143(3)Section 234DSection 9(1)(vi)

cross- objections for all years, raising the following grounds which are common across the years under appeal: Ground No. 1: That the final assessment order dated 10 November 2021, passed u/s. 143(3) r.w.s. 144C(3) of the Act, is barred by limitation, void-ab-initio

Ncr Global Solutions Limited, Ireland vs. Deputy Commissioner of Income-Tax, Circle-2(2)(2), International Tax, New Delhi

In the result, both the appeals of the assessee are allowed as indicated above

ITA 1885/DEL/2025[2022-23]Status: DisposedITAT Delhi30 Oct 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

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

Hearing 06.08.2025 Date of Pronouncement 30.10.2025 ORDER PER BRAJESH KUMAR SINGH, AM This appeal has been preferred by the assessee against the Final Assessment Order dated 02.01.2025 passed by the Learned Assessing Officer (AO) under Section 143(3) read with Sections 144C(13) of the Income ... view of the above, the grounds of objections no. 1 to 8 stand rejected.” 5. Following the above directions, the AO passed the final assessment order u/s 143(3) r.w.s. 144C(13) of the Act, dated 02.01.2025, in which the AO observed that for A.Ys

Aka Ausfuhrkredit-Gesellschaft Mbh, Outside India vs. Deputy Commissioner of Income-Tax Int Tax Circle 1(1)(1), Delhi

In the result, appeal of the assessee is partly allowed

ITA 1766/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Oct 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 115A(1)(b)Section 147Section 148Section 9Section 9(1)(vi)

Hearing 05.08.2025 Date of Pronouncement 30.10.2025 ORDER PER BRAJESH KUMAR SINGH, AM This appeal has been preferred by the assessee against the Final Assessment Order dated 24.01.2025 passed by the Learned Assessing Officer (AO) under Section 147 read with Sections 144C(13) of the Income ... being FTS under Article 12 of the India-Germany DTAA is hereby confirmed.” 7. Thereafter, the AO passed final assessment order on 24.01.2025 u/s 147 r.w.s. 144C of the Act, making the addition of Rs. 85,34,375/-, on account of FTS. 8. Aggrieved with the said final assessment order

Snc Lavalin Inc., Delhi vs. The Assistant Commissioner of Income Tax/ Circle International Tax 3(1)(2), Delhi

In the result, the Appeal of the assessee is allowed, the Stay Application of the assessee is dismissed as infructuous

ITA 1760/DEL/2025[2022-23]Status: DisposedITAT Delhi30 Oct 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 143(3)Section 144C(1)

Hearing 05.08.2025 Date of Pronouncement 30.10.2025 ORDER PER BRAJESH KUMAR SINGH, AM This appeal has been preferred by the assessee against the Final Assessment Order dated 23.01.2025 passed by the Learned Assessing Officer (AO) under Section 143(3) read with Sections 144C(13) of the Income ... Panel directs accordingly.” ITA No.- 1760/Del/2025 SNC Lavalin Inc. 4.1 Upon receipt of the above directions of the DRP, the AO passed the final assessment order u/s 143(3) r.w.s. 144C(13) of the Act on 23.01.2025 at the total income

Volark Leasing Ifsc Pvt. Ltd, Gujarat vs. ACIT/DCIT, Circle, Gandhinagar, Gujarat

In the result, the appeal of the assessee is allowed

ITA 357/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2023-24

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Shri Pancham Sethi, ARFor Respondent: Date of Hearing
Section 143Section 143(1)Section 234BSection 250Section 80Section 80JSection 80L

10CCB along with the return of income had not been filed but the same was made available to the A.O. before passing of final assessment order, the assessee is entitled to claim the deduction u/s 80IA of the Act, in view of the above ratio, we do not find

Vastu Nirman, Mumbai vs. Deputy Commissioner of Income Tax 42(1)(1), Mumbai

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

ITA 4491/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Oct 2025AY 2018-19

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Jignesh ShahFor Respondent: Ms. Kavitha Kaushik, SR DR
Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 43C

adjudicating and considering the fact that the Ld. AO had not given the personal video hearing to the assessee before passing the final assessment order, thereby violating the provision of section 144B of the Act and against the principal of natural justice.” 3. Brief facts of the case are that

Celestial Sverige Aircraft Leasing Worldwide Ab, Stockholm, Sweden vs. Assistant Commissioner of Income -Tax, Circle 1(2)(1), International Tax, Delhi, Civic Centre, Minto Road, New Delhi

In the result, this issue is decided in favour of the assessee/appellant and against the Department

ITA 1479/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Oct 2025AY 2022-23

Aviation Trading 15 Ltd. (supra). 2.1. The ld. Counsel submits that though the assessee has raised other issues viz. tenability of the impugned final assessment order and directions of the Dispute Resolution Panel (DRP) beyond jurisdiction in ground no. 2 and 4 of appeal, respectively, the assessee is not pressing ... assessee has made statement at Bar that he is not pressing ground no. 2 and 4 of appeal challenging validity of final assessment order as well as the directions of the DRP. Accordingly, ground no. 2 and 4 of appeal are dismissed as not pressed. 9. The assessees in appeal

Celestial Aviation Trading 69 Limited, Shannon, Ireland vs. Assistant Commissioner of Income-Tax, Circle 1(2)(1), International Tax, Delhi, Civic Centre, Minto Road, New Delhi

In the result, this issue is decided in favour of the assessee/appellant and against the Department

ITA 1465/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Oct 2025AY 2022-23

Aviation Trading 15 Ltd. (supra). 2.1. The ld. Counsel submits that though the assessee has raised other issues viz. tenability of the impugned final assessment order and directions of the Dispute Resolution Panel (DRP) beyond jurisdiction in ground no. 2 and 4 of appeal, respectively, the assessee is not pressing ... assessee has made statement at Bar that he is not pressing ground no. 2 and 4 of appeal challenging validity of final assessment order as well as the directions of the DRP. Accordingly, ground no. 2 and 4 of appeal are dismissed as not pressed. 9. The assessees in appeal

Celestial Aviation Trading 68 Limited, Shannon, Ireland vs. Assistant Commissioner of Income-Tax, Circle 1(2)(1), International Tax, Delhi, Civic Centre, Minto Road, New Delhi

In the result, this issue is decided in favour of the assessee/appellant and against the Department

ITA 1421/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Oct 2025AY 2022-23

Aviation Trading 15 Ltd. (supra). 2.1. The ld. Counsel submits that though the assessee has raised other issues viz. tenability of the impugned final assessment order and directions of the Dispute Resolution Panel (DRP) beyond jurisdiction in ground no. 2 and 4 of appeal, respectively, the assessee is not pressing ... assessee has made statement at Bar that he is not pressing ground no. 2 and 4 of appeal challenging validity of final assessment order as well as the directions of the DRP. Accordingly, ground no. 2 and 4 of appeal are dismissed as not pressed. 9. The assessees in appeal

Celestial Aviation Trading 14 Limited, Shannon, Ireland vs. Assistant Commissioner of Income-Tax, Circle 1(2)(1), International Tax, Delhi, Civic Centre, Minto Road, New Delhi

In the result, this issue is decided in favour of the assessee/appellant and against the Department

ITA 1420/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Oct 2025AY 2022-23

Aviation Trading 15 Ltd. (supra). 2.1. The ld. Counsel submits that though the assessee has raised other issues viz. tenability of the impugned final assessment order and directions of the Dispute Resolution Panel (DRP) beyond jurisdiction in ground no. 2 and 4 of appeal, respectively, the assessee is not pressing ... assessee has made statement at Bar that he is not pressing ground no. 2 and 4 of appeal challenging validity of final assessment order as well as the directions of the DRP. Accordingly, ground no. 2 and 4 of appeal are dismissed as not pressed. 9. The assessees in appeal

Celestial Aviation Trading 64 Limited, Shannon, Ireland vs. Assistant Commissioner of Income-Tax, Circle 1(2)(1), International Tax, Delhi, Civic Centre, Minto Road, New Delhi

In the result, this issue is decided in favour of the assessee/appellant and against the Department

ITA 1419/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Oct 2025AY 2022-23

Aviation Trading 15 Ltd. (supra). 2.1. The ld. Counsel submits that though the assessee has raised other issues viz. tenability of the impugned final assessment order and directions of the Dispute Resolution Panel (DRP) beyond jurisdiction in ground no. 2 and 4 of appeal, respectively, the assessee is not pressing ... assessee has made statement at Bar that he is not pressing ground no. 2 and 4 of appeal challenging validity of final assessment order as well as the directions of the DRP. Accordingly, ground no. 2 and 4 of appeal are dismissed as not pressed. 9. The assessees in appeal

Celestial Aviation Trading 8 Limited, Shannon, Ireland vs. Assistant Commissioner of Income-Tax, Circle 1(2)(1), International Tax, Delhi, Civic Centre, Minto Road, New Delhi

In the result, this issue is decided in favour of the assessee/appellant and against the Department

ITA 1386/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Oct 2025AY 2022-23

Aviation Trading 15 Ltd. (supra). 2.1. The ld. Counsel submits that though the assessee has raised other issues viz. tenability of the impugned final assessment order and directions of the Dispute Resolution Panel (DRP) beyond jurisdiction in ground no. 2 and 4 of appeal, respectively, the assessee is not pressing ... assessee has made statement at Bar that he is not pressing ground no. 2 and 4 of appeal challenging validity of final assessment order as well as the directions of the DRP. Accordingly, ground no. 2 and 4 of appeal are dismissed as not pressed. 9. The assessees in appeal