“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

Celestial Aviation Trading 62 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 1385/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 36 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 1384/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Oct 2025AY 2022-23

Weg Industries (India) Private Limited, Bengaluru vs. Assessing Officer, Bmtc Building

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

ITA 2501/BANG/2024[2021-22]Status: DisposedITAT Bangalore28 Oct 2025AY 2021-22

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2021-22

For Respondent: Shri Sumeet Khurana , CA

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

GENERAL GROUND ASSESSMENT ORDER IS BAD IN LAW 1. On the facts and in the circumstances of the case and in law, the final assessment order (Order') passed by the Assessment Unit, Income-tax Department ('Ld. AO') dated 22 October 2024, under section 143(3) read with section 144C ... extent prejudicial to the Appellant, is bad in law, factually erroneous and liable to be quashed. LEGAL GROUND FINAL ASSESSMENT ORDER IS BARRED BY LIMITATION 2. On the facts and in the circumstances of the case and in law, the order dated 22 October 2024 passed by Ld. AO, under

Fullerton Financial Holdings Pte. Ltd., Singapore vs. The Assistant Commissioner of Income-Tax - (International Taxation), Circle 2(3)(1) - Mumbai, Mumbai

ITA 1137/MUM/2025[2022-23]Status: DisposedITAT Mumbai28 Oct 2025AY 2022-23

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 143(2)Section 143(3)Section 144CSection 144C(1)Section 144C(13)Section 144C(5)Section 153

independent and without prejudice to each other. Ground No. 1: The Draft Assessment Order, Directions issued by the Dispute Resolution Panel and the Final Assessment Order, are erroneous, contrary to law, without jurisdiction, and bad in law; 1.1 On the facts and in the circumstances of the case ... Mumbai ("the jurisdictional assessing officer") under section 143(3) read with section 144C(1) of the Income-tax Act, 1961 ('the Act'), the final assessment order dated 16 January 2025 passed by the Learned ACIT (International Taxation) 2(3)(1), Mumbai ('Ld. AO') under section 143(3) read with section

Tata Consumer Products Limited (Successor of Tata Coffee Ltd.), Kolkata vs. A.C.I.T., Circle - 4(1), Kolkata

Appeal of the assessee is partly allowed

ITA 2636/KOL/2024[2021-2022]Status: DisposedITAT Kolkata27 Oct 2025AY 2021-2022

Bench: SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 143(3)Section 144Section 144BSection 144C(5)Section 153Section 438Section 43BSection 80MSection 928Section 92B

assessee has filed the present appeal with the following grounds: “1.0 On the facts and circumstances of the case & law, the final assessment order under section 143(3) r.w.s. 144C(13) read with section 144B of the Income Tax Act, 1961 (Act') dated 29 October 2024 passed by the Assessment ... Dispute Resolution Panel (DRP) are erroneous and bad in law. 2.0 On the facts and circumstances of the case & in law, the final assessment order under section 143(3) twa. 144C(13) read with section 1441B of the Act dated October 29, 2024 and Ld. DRP's directions under section

DCIT Central Circle-1(1), Mumbai vs. S Vinodkumar Diamonds Private Limited, Mumbai

Accordingly, Ground No.1 & 2 raised by the Revenue are treated as allowed for statistical purpose

ITA 2282/MUM/2025[2012-13]Status: DisposedITAT Mumbai27 Oct 2025AY 2012-13

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Vartik ChoksiFor Respondent: Shri Pravin Salunkhe

Section 143(3)(ii)Section 144C(3)Section 14ASection 92B

Vide, letter dated 27/01/2017, the Assessee opted not to file objections before the Dispute Resolution Panel and therefore, the Assessing Officer passed the Final Assessment Order, dated 15/02/2017, under Section 143(3)(ii) r.w.s. 144C (3) of the Act and made transfer pricing addition of INR.5 ... Assessment Year 2013-14. 4. Being aggrieved, the Assessee preferred appeal before the Ld. CIT(A) against the Final Assessment Order, dated 15/02/2017, which was disposed off as partly allowed vide impugned order dated 02/01/2025, passed under Section 250 of the Act. The Ld. CIT(A) deleted the transfer pricing

DCIT Central Circle-1(1), Mumbai vs. S Vinodkumar Diamonds Private Limited, Mumbai

Accordingly, Ground No.1 & 2 raised by the Revenue are treated as allowed for statistical purpose

ITA 2281/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Oct 2025AY 2013-14

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Vartik ChoksiFor Respondent: Shri Pravin Salunkhe

Section 143(3)(ii)Section 144C(3)Section 14ASection 92B

Solvay S A, Mumbai vs. The Deputy Commissioner of Income Tax International Tax Circle 4(2)(2), Mumbai

In the result, the appeal is partly allowed

ITA 2071/MUM/2025[2022-23]Status: DisposedITAT Mumbai27 Oct 2025AY 2022-23

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Respondent: Shri Vijay Mehta

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

Hearing : 30.09.2025 Date of Pronouncement : 27.10.2025 ORDER Per Saktijit Dey, Vice President: 1. Captioned is an appeal by the assessee, assailing the final assessment order dated 15.01.2021, passed u/s.143(3) r.w.s.144C(13) of Income Tax Act, 1961 (‘the Act' for short) in pursuance to the directions of learned Dispute Resolution

Swaty Mehta, Delhi vs. Assistant Commissioner of Income Tax, Central Circle-17, Delhi

In the result, the appeals of the assessees are partly allowed as

ITA 2551/DEL/2023[2017-18]Status: DisposedITAT Delhi27 Oct 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.2549/Del/2023 िनधा"रणवष"/Assessment Year:2017-18 बनाम Sonia Mehta Acit, 97, Eastern Avenue, Sainik Farms, Vs. E-2, Central Circle-17, Delhi. Ara Centre, Pan No.Acapm1777A Jhandewalan Extn., New Delhi. अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.2551/Del/2023 िनधा"रणवष"/Assessment Year:2017-18 बनाम Swaty Mehta Acit, 97, Eastern Avenue, Sainik Farms, Vs. E-2, Central Circle-17, Delhi. Ara Centre, Pan No.Acapm1777A Jhandewalan Extn., New Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 153D

Assessing Officer in terms of Section 144A of the Act. She stated that even the Additional CIT/JCIT is involved in the preparation of final assessment order by way of instructing the Assessing Officer issuing final show cause notice. She referred to Paragraph 3.2 of the Manual, which reads as under

Sonia Mehta, Delhi vs. Assistant Commissioner of Income Tax, Central Circle-17, Delhi

In the result, the appeals of the assessees are partly allowed as

ITA 2549/DEL/2023[2017-18]Status: DisposedITAT Delhi27 Oct 2025AY 2017-18

Section 153D

Best City Projects India Pvt. Ltd., New Delhi vs. ITO, Ward- 4(3), New Delhi

In the result, appeal of the assessee is dismissed

ITA 5294/DEL/2019[2008-09]Status: DisposedITAT Delhi27 Oct 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2008-09] M/S Best City Projects India Income Tax Officer, Ward-4(3), Pvt. Ltd. Room No.385A, C.R. Building, Plot No.H-8, 1St Floor, Best Vs New Delhi110002 Plaza, Netaji Subhash Place, Pitampura, New Delhi-110034 Pan-Aaccb7635D Appellant Respondent Assessee By Shri Salil Kapoor, Shri Shivam Yadav Shri Sumit Lal Chandani, Ms. Ananya Kapoor, Advocates. Revenue By Ms. Rajinder Kaur, Cit(Dr) Date Of Hearing 30.07.2025 Date Of Pronouncement 27.10.2025

Section 132Section 143(3)Section 144BSection 153ASection 153BSection 153DSection 254Section 68

prescription contained in section 144C of the Act is sacrosanct and cannot be violated. In the impugned case the AO had passed final assessment order without passing the required draft assessment order. Hon’ble High Court ordered that since passing of draft assessment order and the consequential option

Manorama Patwa, Howrah vs. I.T.O., Ward - 47(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 493/KOL/2025[2015-2016]Status: DisposedITAT Kolkata24 Oct 2025AY 2015-2016

Bench: Shri Pradip Kumar Choubeyshri Rakesh Mishra & Assessment Year: 2015-16 Manorama Patwa…..………….……………………….……….……….……Appellant Shree Shyam Garden – 5Gh, 12, Haradutta Ray Chamaria Road, Howrah-711101.. [Pan: Aunpp4730F] Vs. Ito, Ward-47(1), Kolkata….……………………………….....……...…..…..Respondent Appearances By: Shri A. Kochar, Ar, Appeared On Behalf Of The Appellant. Shri Arun Kr. Meena, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 21, 2025 Date Of Pronouncing The Order : October 24, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 04.02.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’).

Section 144Section 148Section 148ASection 250Section 68

under section 148 of the 1961 Act on or after 1st April 2021. Learned advocate for the respondent was asked as to whether final assessment order has already been passed or not in this case to which he submits that final assessment order has already been passed. He further submits

Juniper Networks Solution India Private Limited, New Delhi vs. Assessment Unit, NFAC Itd, New Delhi

In the result, ground no 3 raised by the assessee is allowed in its favour

ITA 4400/DEL/2024[2020-21]Status: DisposedITAT Delhi24 Oct 2025AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Juniper Networks Solution India Pvt. Ltd., Vs. Assessment Unit, Unit No.Iia, 06Th Floor, Dlf Centre, Nfac Itd, Parliament Street, Connaught Place, New Delhi – 110 001. (Pan : Aaecj1345A) (Appellant) (Respondent) Assessee By : Shri Sachit Jolly, Sr. Advocate Shri Sandeep Bhalla, Advocate Shri Anurag Singhal, Ca Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 05.08.2025 Date Of Order : 24.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 27.07.2024 Passed By The Income Tax Department, Assessment Unit U/S 143(3) Read With Section 144C(13)/144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

For Appellant: Shri Sachit Jolly, Sr. AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 92C

that the operating margin of the assessee is within the ALP, accordingly, the adjustment was reduced to nil. 9. Against the order of Final assessment order and directions of DRP on the issue of rejecting the various objections raised before the DRP, which DRP had sustained the findings

Travelport Global Distribution System Bv, Netherland vs. The Assistant Commissioner of Income Tax, New Delhi

In the result, Appeal of the Assessee is allowed

ITA 1628/DEL/2024[AY 2016-17]Status: DisposedITAT Delhi24 Oct 2025

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Travelport Global Distribution Vs Assistant Commissioner Of System Bv, Taurusavenue Income Tax, Circle 33A-2132 Ls, Po Box 3064- International Taxation 1(3)(1) 2130Kb, Hoofddrop, The Civic Centre, Minto Road, Netherlands, Netherland New Delhi Pan: Aaccg2258D Appellant Respondent Assessee By Sh. S. K. Agarwal, Adv, Sh. Vibha Bansal, Ca & Sh. Arihant Jain, Ca Revenue By Sh. Saroj Kumar Dubey, Cit(Dr) Date Of Hearing 28/08/2025 Date Of Pronouncement 24/10/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Final

Section 144C(13)Section 147Section 148Section 148ASection 149Section 4Section 44C

Hearing 28/08/2025 Date of Pronouncement 24/10/2025 ORDER PER YOGESH KUMAR, U.S. JM: The present appeal is filed by the Assessee against the Final Assessment Order dated 12/03/2024 passed u/s 147 r.w.Section144C(13) of the Income Tax Act, 1961 ('Act' for short) pertaining to Assessment Year 2016-17. 2. Brief facts ... chargeable to tax in the hands of the Assessee in India, has escaped assessment for the Assessment Year 2016-17. A Final assessment order came to be passed on 12/03/2024 u/s 147 r.w. Section 44C (13) of the Act which is under challenge by the Assessee. 3. The Ld. Counsel

Six Continents Hotels Inc, Gurgaon vs. ACIT, Circle-3(1)(2), International Taxation, New Delhi

In the result, Appeals of the Assessee in ITA No

ITA 1459/DEL/2022[2018-19]Status: DisposedITAT Delhi24 Oct 2025AY 2018-19

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 143(3)Section 144C(13)

verify the invoices and back-up statements of TACP and other reimbursements in AY 2018-19. Thereafter, the Ld. AO while issuing the final assessment order for both the years, held that MRC and other reimbursements related receipts are taxable as FTS/ FIS under the Act and India-USA DTAA ... Aggrieved by the Final Assessment Orders dated 14/02/2021 and 26/04/2022 for Assessment Year 2017-18 and 2018-19 respectively, the Assessee preferred Appeal before this Tribunal. The Co-ordinate Bench of the Tribunal vide order dated 17th November, 2023, quashed the Final Assessment Orders in both the years

Six Continents Hotels Inc., Usa vs. ACIT Circle- 3 (1)(2) - International Taxation, New Delhi

In the result, Appeals of the Assessee in ITA No

ITA 373/DEL/2021[2017-18]Status: DisposedITAT Delhi24 Oct 2025AY 2017-18

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 143(3)Section 144C(13)

Vodafone Idea Ltd. (Earlier Knwon As Vodafone Mobile Services Ltd.), Mumbai vs. ACIT, . Circle-26(2), New Delhi

In the result, all above said grounds are allowed for statistical purpose

ITA 8361/DEL/2019[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shriyogesh Kumar U.S.Vodafone Idea Ltd Vs. Acit, (Earlier Known As Vodafone Circle-26(2), Mobile Services Ltd) New Delhi 10Th Floor, Birla Centurion, Century Mills Compound, Pandurang Budhkar Marg, Worli, Mumbai, Maharastra (Appellant) (Respondent) Pan: Aaacb2100P

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Shri S. K,. Jadav, CIT DR

Section 115JSection 143(3)Section 144C(5)Section 92C

purpose of MAT calculation. The said adjustment was upheld by the DRP. Pursuant thereto, the A.O., in terms of the impugned final Assessment Order, made an adjustment amounting to INR 1,879,70,00,000 to the book profits under section 115JB of the Act. 3. Aggrieved with the above ... categorized payments to IBM as one related to IT services and one related to hardware- both of which were to be capitalized.In the final assessment order, it disallowed a total of Rs. 96,71,96,490/- and made addition of Rs. 77,37.57,132/-, after allowing deduction of amortized amount

Netflix Entertainment Services India LLP, Mumbai vs. Deputy Commissioner of Income Tax- Circle 23(1), Mumbai

In the result, appeal of the assessee is partly

ITA 6857/MUM/2024[2021-22]Status: DisposedITAT Mumbai17 Oct 2025AY 2021-22

Section 143(3)Section 144C(5)Section 234ASection 270ASection 40

Hearing 24/07/2025 Date of Pronouncement 17/10/2025 आदेश / ORDER PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the assessee against final assessment order dated 25/10/2024 passed u/s.143(3) r.w.s.144C (13) for the A.Y.2021-22 in pursuance of direction given by the DRP u/s.144C(5) dated 28/09/2024. 2. In various ... relation to the payment of distribution fee (ground No.5- 13) • Assailing the enhancement by the DRP u/s.40(a)(i) (Ground no.14-16); • Assailing final assessment order has been without jurisdiction (Ground No.2-4); • Error in computation of assessed income (Ground No.17); • Levy of excess interest u/s.234A, 234B and 234D

Mitu Mohindru, Delhi vs. ACIT Circle-Intl Tax 2(2)(1), Delhi

In the result, the Appeal of the Assessee is allowed

ITA 2134/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Oct 2025AY 2016-17

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Mitu Mohindru Vs Acit C/O Ca Vaibhavgoel Circle, International 75 Navyug Market Taxtdaion-2(2)(1) 1St Floor, Ghaziabad Delhi Uttar Pradesh Pan: Aqjpm9070D Appellant Respondent Assessee By Sh. Vaibhav Goel, Ca Revenue By Sh. Saroj Kumar Dubey, Cit Dr Date Of Hearing 26/08/2025 Date Of Pronouncement 17/10/2025 Order

Section 143(3)Section 144C(13)Section 147Section 147rSection 69

Pronouncement 17/10/2025 ORDER PER YOGESH KUMAR, U.S. JM: The present appeal is filed by the assesseepertaining to Assessment Year 2016-17 challenging the Final Assessment Order dated 27/01/2025 passed by Assistant Commissioner of Income Tax, Circle International Taxation 2(2)(1) u/s143(3) Section 147r.w.Section 144C(13) of the Income ... 144C (13) of the Act by making an addition of Rs. 1,23,00,000/- u/s 69 of the Act.Aggrieved by the Final Assessment order passed u/s 147 r.w. Section 144C(13) of the Act, the Assessee preferred the present Appeal. 3. The Ld. Counsel for the Assessee submittedthat

Raheja Developers Limited, New Delhi vs. DCIT, Central Circle 19, New Delhi

ITA 2284/DEL/2023[2012-13]Status: DisposedITAT Delhi17 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No.2283/Del/2023 (A.Y 2011-12) Raheja Developers Limited Vs Acit W4D-204/5, Keshav Kunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent I.T.A. No.2284/Del/2023 (A.Y 2012-13) Raheja Developers Limited Vs Acit W4D-204/5, Keshavkunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent Assessee By Sh. Neeraj Jain, Ca& Sh. P. K. Mishra, Ca Revenue By Ms.Pooja Swaroop, Cit (Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 17/10/2025

Section 143(3)Section 147Section 148Section 14ASection 68

deliberately filed the objection at the fag end of the assessment proceedings. The said objection has been decided by the A.O. in the final assessment order, therefore, the Ground No. 4 of the Assessee requires to be dismissed. 15. We have heard both the parties and perused the material available