“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

Deepak Agarwal, Delhi vs. DCIT, Central Circle- 25, Delhi

ITA 2305/DEL/2025[2013-14]Status: DisposedITAT Delhi15 Oct 2025AY 2013-14

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 148(2)Section 151Section 153ASection 68

cannot be sustained when there is a total variation between the reasons recorded u/s 148A of the Act and the final assessment order. Reliance was placed on Hon’ble Punjab and Haryana High court decision in case of Dinesh Singla 474 ITR 532, where Hon’ble High Court has held ... ACIT 474 ITR 466 have upheld same principle. Admittedly no adverse inference is drawn on reopening ground of Rs 49.69 cr in final assessment order. Admittedly The alleged estimated commission income as finally added in impugned assessment is no where subject matter of reopening order u/s 148A

Schneider Electric Private Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle 22(2), C. R. Building, Delhi

The appeal is allowed partly

ITA 5589/DEL/2024[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2021-22 Schneider Electric Private Vs Dcit, Limited, Circle 22(2), C-56, Mayapuri Industrial Area, Delhi. Phase-2, West Delhi, Delhi – 110 064. Pan: Abacs1671F (Appellant) (Respondent) Assessee By : Shri Rohit Tiwari, Advocate & Ms Tanya, Advocate. Revenue By : Shri S.K. Jadhav, Cit-Dr Date Of Hearing : 20.08.2025 Date Of Pronouncement : 15.10.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Final Assessment Order Dated 28.10.2024 Passed By The Assessment Unit, Income-Tax Department (Hereinafter Referred To As The Ld. Ao) U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For Ay 2021-22. 2. Heard & Perused The Records. On The Basis Of Submission & Material On Record It Comes Up That Assesse/ Appellant (Sepl) Was Incorporated In 2018 As A Subsidiary Of Schneider Electric Industries Sas (A Wholly Owned Subsidiary Of Schneider Electric Se) & Belgium. It Is A Private Limited Company

For Appellant: Shri Rohit Tiwari, Advocate &For Respondent: Shri S.K. Jadhav, CIT-DR

Section 143(3)

Date of Hearing : 20.08.2025 Date of Pronouncement : 15.10.2025 ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the Assessee against the final assessment order dated 28.10.2024 passed by the Assessment Unit, Income-tax Department (hereinafter referred to as the Ld. AO) u/s 143(3) r.w.s. 144C(13) r.w.s. 144B

Dharampal Satyapal Ltd., New Delhi vs. ACIT Central Circle 29, New Delhi

ITA 5519/DEL/2024[2015-16]Status: DisposedITAT Delhi15 Oct 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2015-16 Dharampal Satyapal Ltd., Vs. Acit, 98, Okhla Industrial Estate Central Circle-29, Phase Iii, New Delhi. Tehkhand, New Delhi – 110 020. Pan: Aaacd0132H (Appellant) (Respondent) Assessee By : Shri R.S. Singhvi; Shri Satya Jeet Goel; & Shri Rajat Garg, Cas Revenue By : Shri Amit Jain, Cit-Dr Date Of Hearing : 11.09.2025 Date Of Pronouncement : 15.10.2025 Order

For Appellant: Shri R.S. SinghviFor Respondent: Shri Amit Jain, CIT-DR

Section 115JSection 144CSection 147Section 148Section 148ASection 149Section 69ASection 80ISection 92C

Date of Hearing : 11.09.2025 Date of Pronouncement : 15.10.2025 ORDER PER ANUBHAV SHARMA, JM: This is an appeal preferred by the Assessee against the final assessment order dated 29.10.2024 passed u/s 147 r.w.s. 144C(13) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) by the ACIT, Central ... respect of VAT evasion issue and issue of reopening u/s 147 of the Act. Accordingly, the assessing officer passed the final assessment order u/s 147 r.w.s. 144C(13) dated 29/10/2024. 3. In above background, the appellant has challenged impugned assessment order before us raising following grounds:- “That on the facts

Assimilate Solutions India Pvt. Ltd., Delhi vs. DCIT Circle, 1(1), Delhi

In the result, the ground raised by the assessee in this regard is dismissed

ITA 5357/DEL/2024[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Vimal Kumarassimilate Solutions India Private Limited, Vs. Dcit/Acit, C/O Sanjiv Sapra & Associates Llp, Circle 1 (1), Chartered Accountants, New Delhi. C – 763, New Friends Colony, New Delhi – 110 025. (Pan :Aakca4501H) (Appellant) (Respondent) Assessee By : Shri Sanjiv Sapra, Ar Revenue By : Shri Dharam Veer Singh, Cit Dr Date Of Hearing : 30.07.2025 Date Of Order : 15.10.2025 Order Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against Assessment Order Dated 31.12.2015 Passed By The Assessment Unit, Income Tax Department Under Section 143(3) Read With Section 144C(13)R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2021-22 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act. 2. M/S. Assimilate Solutions India Private Limited, The Assessee Was Incorporated On 19.04,2012 & Is Engaged In The Business Of Providing

For Appellant: Shri Sanjiv Sapra, ARFor Respondent: Shri Dharam Veer Singh, CIT DR

Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)

appeal :- “Based on the facts and circumstances of the case, Assimilate Solutions India Private Limited ('the Appellant') respectfully prefer an appeal against the final assessment order dated 26.09.2024 passed by the Assessing Officer ('the AO') under Section 143 (3) r.w.s 144C (13)/144B of the Income ... have been quashed/annulled set aside by the DRP since such orders as passed were bad in law and unsustainable. (viii) That the final assessment order dated 26.09.2024 under section 143(3) r.w.s. 144C(13)/144B of the Act as passed by the AO in pursuance to the directions dated

Tupperware India Private Limited, Connaught Place New Delhi vs. National Faceless Assessment Centre Through Deputy Commissioner of Income Tax, Ip Estate New Delhi

The appeal is allowed partly

ITA 4475/DEL/2024[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year : 2020-21

Section 143(3)Section 37Section 92BSection 92C

claimed by the Appellant in its return of income, thereby making additions/disallowances of INR 235,001,701 in the final assessment order. Corporate Tax Grounds: 3. On the facts and circumstances of the case, and in law, while computing assessed income of the Appellant, the Ld. AO erred in considering

Alfanar Energy Private Limited, Gurugram, Haryana, India vs. The Deputy Or Assistant Commissioner of Income Tax, Circle 1(1), Gurugram, Haryana, India

The appeal is allowed partly with consequences to follow as per the directions given to AO/TPO above

ITA 4439/DEL/2024[AY 2020-21]Status: DisposedITAT Delhi15 Oct 2025

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2020-21 Alfanar Energy Private Limited, Vs Dcit, 16Th Floor, Building No.5, Circle-1(1), Block-C, Dlf Cyber City, Gurugram. Phase Iii, Gurugram, Haryana – 122 002. Pan: Aapca2671M (Appellant) (Respondent) Assessee By : Shri Vishal Kalra, Advocate; Ms Reema Grewal, Ca; & Ms Snigdha Gautam, Advocate Revenue By : Shri S.K. Jadhav, Cit-Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 15.10.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Final Assessment Order Dated 29.07.2024 Of The Dy. Commissioner Of Income-Tax, Circle 1(1), Gurugram (Hereinafter Referred As ‘The Ld. Ao’) For Assessment Year 2020-21 Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’). 2. The Assessee Is Part Of The Multinational Group, Arabian Trading Group Which Is Based Out Of Kingdom Of Saudi Arabia & Is Engaged In Generating, Developing, Accumulating, Distributing & Supplying Electricity By Setting Renewable Energy Power Plants. This Is The First Year Of The Assessment Of The Assessee. During The Year, The Assessee Has Undertaken The Following International Transactions:- International Transactions Transfer Pricing Method Total Value Of International Transactions (In Inr) Issue Of Compulsorily Other Method 2,44,77,26,400 Convertible Debentures (Ccds) Interest On Ccds Comparable Uncontrolled 46,52,90,098 Price (Cup) Method Issue Of Equity Shares Other Method 45,04,31,700

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri S.K. Jadhav, CIT-DR

Section 143(3)

Date of Hearing : 28.07.2025 Date of Pronouncement : 15.10.2025 ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the assessee against the final assessment order dated 29.07.2024 of the Dy. Commissioner of Income-tax, Circle 1(1), Gurugram (hereinafter referred as ‘the Ld. AO’) for Assessment Year 2020-21 passed

Mannohar Lal Hira Lal Ltd, Ghaziabad vs. ITO, Ward- 2(1)(4), Ghaziabad

In the result, the appeal of the assessee is allowed

ITA 2663/DEL/2022[2017-18]Status: DisposedITAT Delhi15 Oct 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2017-18 Mannohar Lal Hira Lal Ltd. Vs. Ito, Ward 2(1)(4) C/O Praveen K. Agarwal & Ghaziabad Associates Cgo Complex-1 D-17 Third Floor Ghaziabad-201001 Rdc Raj Nagar Ghaziabad Uttar Pradesh-201001 (Pan: Aabcm1295R) (Appellant) (Respondent) Appellant By : Shri Sidhantgoyal Ca Respondent By: Shri Ashok Kumar Pandey, Sr. Dr.

For Appellant: Shri SidhantGoyal CAFor Respondent: Shri Ashok Kumar Pandey, Sr. DR

Section 143(2)

facts and in the circumstances of the case and in law the AO has made an entirely new addition in the final assessment order without an opportunity of being heard to the assessee in the show cause notice. Thus being violative of principles of natural justice, the proceeding are null

Mukesh S Kedia HUF, Ahmedabad vs. Income Tax Officer, Ahmedabad

In the result, all four appeals filed by the assessee are allowed for statistical purposes

ITA 678/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad14 Oct 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Rasesh Shah, ARFor Respondent: Shri Abhijit, Sr DR

Section 132Section 144Section 147Section 148Section 250Section 68Section 69A

Officer issued show-cause notices dated 24.03.2022, fixing the hearing on 26.03.2022, thereby affording the assessee only one day to respond and the final assessment orders were passed shortly thereafter on 29.03.2022. The Ld. AR, therefore, contended that it is a clear violation of the principles of natural justice. With

Mukesh S Kedia HUF, Ahmedabad vs. Income Tax Officer, Ahmedabad

In the result, all four appeals filed by the assessee are allowed for statistical purposes

ITA 677/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad14 Oct 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Rasesh Shah, ARFor Respondent: Shri Abhijit, Sr DR

Section 132Section 144Section 147Section 148Section 250Section 68Section 69A

Mukesh S Kedia HUF, Ahmedabad vs. Income Tax Officer, Ahmedabad

In the result, all four appeals filed by the assessee are allowed for statistical purposes

ITA 676/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad14 Oct 2025AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Rasesh Shah, ARFor Respondent: Shri Abhijit, Sr DR

Section 132Section 144Section 147Section 148Section 250Section 68Section 69A

Mukesh S Kedia HUF, Ahmedabad vs. Income Tax Officer, Ahmedabad

In the result, all four appeals filed by the assessee are allowed for statistical purposes

ITA 675/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad14 Oct 2025AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Rasesh Shah, ARFor Respondent: Shri Abhijit, Sr DR

Section 132Section 144Section 147Section 148Section 250Section 68Section 69A

DCIT, New Delhi vs. M/S. Vodafone Essar Digilink Ltd., New Delhi

ITA 1158/DEL/2015[2010-11]Status: DisposedITAT Mumbai14 Oct 2025AY 2010-11

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

For Appellant: Shri Ketan Ved & Shri Ninad PatadeFor Respondent: Shri Pankaj Kumar

Section 143(1)Section 143(3)Section 144C(1)Section 144C(5)Section 92C

Rahul Chaudhary, Judicial Member: 1. These are Cross-Appeals pertaining to Assessment Year 2010-2011 arising from the Final Assessment Order, dated 27/01/2015, passed by the Assessing Officer under Section 144C(1) read with Section 143(3) of the Income Tax Act, 1961 [hereinafter referred to as ‘the ITA No.1073/Del/2015 ... Draft Assessment Order which were disposed off vide Order dated 18/12/2014, granting partial relief to the Assessee. Thereafter, the Assessing Officer passed the Final Assessment Order, ITA No.1073/Del/2015 & ITA No.1158/Del/2015 Assessment Year 2010-2011 dated 27/01/2015, as per directions issued by the DRP vide Order dated 18/12/2014. Both, the Revenue

Vodafone Digilink Limited, New Delhi vs. Deputy Commissioner of Income-Tax, New Delhi

ITA 1073/DEL/2015[2010-11]Status: DisposedITAT Mumbai14 Oct 2025AY 2010-11

Section 143(1)Section 143(3)Section 144C(1)Section 144C(5)Section 92C

Rahul Chaudhary, Judicial Member: 1. These are Cross-Appeals pertaining to Assessment Year 2010-2011 arising from the Final Assessment Order, dated 27/01/2015, passed by the Assessing Officer under Section 144C(1) read with Section 143(3) of the Income Tax Act, 1961 [hereinafter referred ... Draft Assessment Order which were disposed off vide Order dated 18/12/2014, granting partial relief to the Assessee. Thereafter, the Assessing Officer passed the Final Assessment Order, ITA No.1073/Del/2015 & ITA No.1158/Del/2015 Assessment Year 2010-2011 2 dated 27/01/2015, as per directions issued by DRP vide Order dated 18/12/2014. Both, the Revenue

Steelwill Globotech Private Limited, Faridabad, Haryana vs. Income Tax Officer, Ward 1(4), Faridabad, Haryana

In the result, ground nos

ITA 1466/DEL/2025[2018-19]Status: DisposedITAT Delhi14 Oct 2025AY 2018-19

For Appellant: Shri Nikhil Goyal (Through VC), &For Respondent: Shri M.S Nethrapal, CIT(DR)

Section 144CSection 147Section 148Section 148ASection 92C

bank account during the Financial Year 2017-18. However, no addition was made by the Assessing Officer (AO) while passing final assessment order on the reasons for which assessment was reopened. Addition was made only in respect of Transfer Pricing Adjustment on account of interest on loan advances Rs.9

Kalyanasundaram Chandrasekaran, Chennai vs. Income Tax Officer International Taxation Ward 1(1), Chennai

In the result, appeal filed by the assessee is dismissed as

ITA 1514/CHNY/2025[2016-17]Status: DisposedITAT Chennai13 Oct 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Respondent: Mr.Gautham S. Mukundan

Section 144Section 144C

assessment order u/s.144C of the Act was passed by the AO on 30.09.2024 and thereafter is noted to have Kalyanasundaram Chandrasekaran :: 2 :: passed final assessment order on 28.11.2024. The Ld.AR, Shri R. Harshvardan, Advocate, has sought the leave of this Tribunal for withdrawing the ibid appeal with the liberty

Warner Bros Distributing Inc., United States of America vs. The Assistant Commissioner of Income Tax, Circle International Taxation 4(3)(2), Mumbai

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

ITA 3411/MUM/2023[AY 2020-21]Status: DisposedITAT Mumbai13 Oct 2025

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Deepak Chopra (virtually present)For Respondent: Shri Satya Pal Kumar, CIT (DR)

Section 143(3)Section 144CSection 144C(5)Section 9(1)(vi)

Hearing – 16/07/2025 Date of Order - /10/2025 ORDER PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeal against the impugned final assessment order dated 30.07.2023, passed under section 143(3) read with section 144C of the Income Tax Act, 1961 (“the Act”) pursuant to the directions issued ... India as a fair and reasonable percentage. 8. In conformity with the directions issued by the learned DRP, the AO passed the impugned final assessment order, inter alia, making the addition of Rs.34,78,85,036/- to be the income of the assessee assessable as business income. Being aggrieved

Franklin Templeton Internaitoanl Services (I) P.Ltd, Mumbai vs. DCIT (OSD) 3(1), Mumbai

In the result the appeal filed by the assessee for assessment year 2007-08 and 2008-09 stands partly allowed

ITA 7216/MUM/2012[2008-09]Status: DisposedITAT Mumbai13 Oct 2025AY 2008-09

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 133(6)Section 92D

Hearing 16.07.2025 Date of Pronouncement 13.10.2025 ORDER Per: Smt. Beena Pillai, J.M.: The Present appeals filed by the assessee arises out of final assessment order dated 21/09/2011 and 27/09/2012 passed by Ld.ACIT-Circle-3(1), Mumbai, for assessment years 2007-08 and 2008-09 respectively, on following grounds of appeal ... 2008-09.The Ld.AR submitted that the issues raised therein is to challenging validity and legality of the draft assessment order, DRP directions and final assessment order. 2.1 The Ld.AR at the outset submitted that, these issues may be treated as academic and is not pressed by the assessee. 2.2 Considering

Franklin Templeton International Services (I) P. Ltd, Mumbai vs. Asst CIT 3(1)(OSD), Mumbai

In the result the appeal filed by the assessee for assessment year 2007-08 and 2008-09 stands partly allowed

ITA 6986/MUM/2011[2007-08]Status: DisposedITAT Mumbai13 Oct 2025AY 2007-08

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 133(6)Section 92D

Alankit Limited, Delhi vs. DCIT, Circle-2(2), Delhi

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

ITA 3207/DEL/2025[2019-20]Status: DisposedITAT Delhi13 Oct 2025AY 2019-20

Bench: SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER and SHRIS.RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Sumit Lal Chandani, AdvocateFor Respondent: Shri Om Prakash, Sr. DR

Section 115Section 143(1)Section 153ASection 36Section 36(1)(va)Section 37

profit under section 1151B of the Act on account of deferred tax liability, which has resulted in a double addition. 8. That the final assessment order passed under section 153A does not include or refer to the said disallowance, rendering the earlier adjustment under section

Lear Automotive India P. Ltd., Pune vs. Assistant Commissioner of Income Tax, Circle-8, Pune

ITA 554/PUN/2024[2016-17]Status: DisposedITAT Pune10 Oct 2025AY 2016-17

For Appellant: Shri Dhanesh Bafna &For Respondent: Shri Prakash L. Pathade

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

Dispute Resolution Panel (“DRP”). However, the assessee's objections were rejected by the Ld. DRP vide its order dated 22.03.2021. Pursuant thereto, the final assessment order was passed by the Ld. AO u/s 143(3) r.w.s. 144C(13) of the Act on 08.05.2021 at assessed income of Rs.137 ... thus directed the Ld. AO to give effect to the aforesaid findings and directions, pursuant to which the Ld. AO passed the final assessment order on 22.01.2024 u/s 143(3) r.w.s. 254 read with section 144B of the Act. 4. Aggrieved by the adjustment sustained with respect to the allocation