“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

M/S Atul Kumar Bansal, New Delhi vs. ACIT, New Delhi

In the result, all the appeals of the assessee are allowed and all 7

ITA 1693/DEL/2017[2010-11]Status: DisposedITAT Delhi10 Sept 2025AY 2010-11

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

For Appellant: Shri V. K. Sabharwal, AdvFor Respondent: Shri Jitender Singh, CIT DR

Section 153ASection 153DSection 281B

examine the approval dated 27.09.2021, we find that in para 3, the ld. competent authority has mentioned as follows:- “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

M/S Atul Kumar Bansal, New Delhi vs. ACIT, New Delhi

In the result, all the appeals of the assessee are allowed and all 7

ITA 1692/DEL/2017[2009-10]Status: DisposedITAT Delhi10 Sept 2025AY 2009-10

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

For Appellant: Shri V. K. Sabharwal, AdvFor Respondent: Shri Jitender Singh, CIT DR

Section 153ASection 153DSection 281B

M/S Atul Kumar Bansal, New Delhi vs. ACIT, New Delhi

In the result, all the appeals of the assessee are allowed and all 7

ITA 1691/DEL/2017[2008-09]Status: DisposedITAT Delhi10 Sept 2025AY 2008-09

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

For Appellant: Shri V. K. Sabharwal, AdvFor Respondent: Shri Jitender Singh, CIT DR

Section 153ASection 153DSection 281B

Anil Kumar Batar, Sikar vs. PCIT-Jaipur-2, Jaipur

In the result, the appeal of the assessee is allowed

ITA 418/JPR/2025[2018-19]Status: DisposedITAT Jaipur09 Sept 2025AY 2018-19

For Appellant: Shri Shrawan Kumar Gupta, Adv. &For Respondent: Shri Gorav Avasthi, JCIT-DR

Section 143(3)Section 144BSection 147Section 263

view of the AO-Assessment also does not become erroneous where queries raised during the assessment proceedings are not recorded in the final assessment order. 9. 2. On perusal of the order in the present case the ld. CIT has taken action u/s 263 only on the assumption and presumption

Dassault Systemes Solidworks Corporation, C/O Deloitte Haskins and Sells LLP vs. The Asst. Commissioner of Income - Tax, Mumbai

In the result, appeal of the assessee is allowed

ITA 1879/MUM/2025[2022-2023]Status: DisposedITAT Mumbai09 Sept 2025AY 2022-2023

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Anikesh Banerjee, Hon’Ble

For Appellant: Revenue byFor Respondent: Shri Satya Pal Kumar, CIT D/R

Section 143(3)Section 144C(13)Section 234BSection 9(1)(vi)

pertaining to AY 2022- 23. 2. The grievance of the assessee can be summarized as under:- “1. To quash the final assessment order passed by the AO under section 143(3) read with section 144C(13) of the Act. 2. To hold the income of the Appellant amounting

Gemological Institute of America, Inc., United States vs. The Assistant Commissioner of Income-Ta (International Taxation) - Circle 2(3)(2), Mumbai

In the result, appeals of the assesse are allowed partly for statistical

ITA 1293/MUM/2025[2022-23]Status: DisposedITAT Mumbai09 Sept 2025AY 2022-23

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Anikesh Banerjee, Hon'Ble

For Appellant: Shri J.D. Mistry, Sr. Adv. & Shri Niraj Sheth, A/RsFor Respondent: Shri Satya Pal Kumar, CIT D/R a/w Shri Krishna Kumar, Sr. D/R

Section 144C(13)Section 147Section 148

assessee had a right to appeal against the order of DRP. However, now 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 ... Particulars Royalty income offered to tax by the Appellant (A) Date Amount (in Rs.) 4,54,85,72,731 Date of the Final Assessment Order passed u/s.147 r.w.s.144C(13) of the Income-tax Act, 1961 30 December 2024 Date when the Advance Pricing Agreement ["APA"] was concluded between GIA India

Gemological Institute of America, Inc., United States vs. The Assistant Commissioner of Income-Tax (International Taxation), Circle 2(3)(2) - Mumbai, Mumbai

In the result, appeals of the assesse are allowed partly for statistical

ITA 1292/MUM/2025[2019-20]Status: DisposedITAT Mumbai09 Sept 2025AY 2019-20

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Anikesh Banerjee, Hon'Ble

For Appellant: Shri J.D. Mistry, Sr. Adv. & Shri Niraj Sheth, A/RsFor Respondent: Shri Satya Pal Kumar, CIT D/R a/w Shri Krishna Kumar, Sr. D/R

Section 147Section 148

assessee had a right to appeal against the order of DRP. However, now 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 ... following charts:- AY: 2019-20 Particulars Date Amount (in Rs.) (A) Royalty income offered to tax by the Appellant Date of the Final Assessment Order passed u/s.147 r.w.s.144C(13) of the Income-tax Act, 1961 30 December 2024 4,54,85,72,731 Date when the Advance Pricing Agreement

Ust Global Technology Services (India) Private Limited, Kochi vs. DCIT, Corporate Circle 2(1), Kochi

In the result, appeal filed by the assessee stands partly allowed

ITA 1071/COCH/2024[2021-22]Status: DisposedITAT Cochin08 Sept 2025AY 2021-22

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary

For Appellant: Respondent byFor Respondent: Shri Rajakannam, Advocate

Section 143Section 92C

Date of Pronouncement: 22.08.2025 08.09.2025 ORDER Per Inturi Rama Rao, AM: This is an appeal filed by the Assessee-company directed against the final assessment order dated 23/10/2024 passed u/s. 1433 r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (for short, 'the Act') for Assessment Year ... Panel (DRP). The DRP had dismissed all the objections raised by the appellant. After receipt of the directions issued by the DRP, the final assessment order was passed vide order dated 23/10/2024 passed u/s. 143(3) r.w.s. 144C(13) r.w.s. 144B of the Act at a total income

M/S.Joy Alukkas India P. Ltd, Cochin vs. The ACIT, Cochin

In the result, the appeal filed by the Assessee stands partly allowed for statistical purposes

ITA 38/COCH/2017[2012-13]Status: DisposedITAT Cochin08 Sept 2025AY 2012-13

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

For Appellant: Smt. Parvathy Ammal, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 143(3)Section 36(1)(iii)Section 36(1)(viii)Section 92C

Inturi Rama Rao, AM: These are the appeals filed by the assessee-company directed against the different final assessment orders dated 29/01/2016, 27/12/2016 & 30/10/2017 passed u/s. 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (for short, 'the Act') for Assessment Years

M/S.Joy Alukkas India P. Ltd, Trichur vs. The ACIT, Ernakulam

In the result, the appeal filed by the Assessee stands partly allowed for statistical purposes

ITA 119/COCH/2016[2011-12]Status: DisposedITAT Cochin08 Sept 2025AY 2011-12

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

For Appellant: Smt. Parvathy Ammal, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 143(3)Section 36(1)(iii)Section 36(1)(viii)Section 92C

Lowes Services India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle 4(1)(1), Bangalore

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

ITA 1734/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore08 Sept 2025

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Shri Chavali Narayan, ARFor Respondent: Dr. Divya K J, CIT(DR)(ITAT), Bengaluru

Section 143(1)Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 36(1)(va)Section 80G

direction of the ld. DRP to charge interest rate on the basis of LIBOR rate at 5.817% p.a. 10. Based on this, the final assessment order was passed on 19.7.2024 wherein the only Transfer pricing issue of interest on overdue receivable remained with upward TP adjustment of Rs.1 ... disallowance of Rs.132,825 was a double addition because it was first disallowed u/s. 143(1) and subsequently once again while framing the final assessment order. The ld. DR submitted that the same may be verified. 20. In view of the above facts, we direct the ld. AO that

Virendra M Gaidhane, Mumbai vs. ITO, Ward 2(3)(1), Mumbai

In the result, assessee’s appeal in ground no-1 is allowed

ITA 64/MUM/2025[2022-23]Status: DisposedITAT Mumbai05 Sept 2025AY 2022-23

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Nishit Gandhi a/w Ms. Aadnya BhandariFor Respondent: Shri Krishna Kumar (SR DR)

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

03/09/2025 Date of pronouncement : 05/09/2025 O R D E R Per Anikesh Banerjee (JM): This appeal of the assessee is directed against the final assessment order of the passed by the Learned Income-tax Officer, Int. Tax Ward 2(3)(1), Mumbai, (in short, ‘Ld.AO’) order passed under section ... after considering the submissions, partly allowed the application of the assessee. Pursuant thereto, the Ld. AO passed the final assessment order wherein the additions under three issues were sustained. Being further aggrieved, the assessee has preferred the present appeal before us. Ground 1 : Related to addition of FD in ICICI

M/S Grob-Werke Gmbh & Co. Kg, Germany vs. The Assistant Commissioner of Income Tax, Intl Txn Circle, Vizag, Visakhapatnam

In the result, appeal of the assessee is partly allowed

ITA 176/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam04 Sept 2025AY 2022-23

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.176/Viz/2025 (निर्धारण वर्ा/ Assessment Year:2022-23) Vs. M/S. Grob – Werke Gmbh & Co. Kg Acit Industriestrasse 4, 87719 Mindelheim International Taxation Circle Income Tax Office Germany, Pincode - 87719 Infinity Towers Sankaramatam Road [Pan:Aaifg4270G] Visakhapatnam - 530016 करदाता का प्रतततितित्व/ Assessee Represented By : Shri Nikhil Ajit Mutha, Ca : Shri Badicala Yadagiri, Cit(Dr) राजस्व का प्रतततितित्व/ Department Represented By सुिवाई समाप्त होिे की ततति/ Date Of Conclusion Of Hearing : 07.08.2025 घोर्णध की तधरीख/Date Of Pronouncement : 04.09.2025

Section 115ASection 129Section 142(1)Section 143(2)Section 143(3)Section 195

आदेश /O R D E R PER SHRI S BALAKRISHNAN, ACCOUNTANT MEMBER: 1. This appeal is filed by the assessee against the final assessment order passed by the Ld. Assessing Officer [hereinafter in short “Ld. AO"] under section 143(3) r.w.s. 144C(13) of Income Tax Act, 1961 (in short ... order and thereby dismissed the objection raised by the assessee. Giving effect to the direction of the DRP, the Ld. AO passed the final assessment order. 6. On being aggrieved by the final assessment order the assessee is in appeal before us by raising following grounds of appeal: - 1. Ground

Praveen Kumar Patwa HUF, Howrah vs. ITO, Ward-47(2), Kolkata

In the result, the appeal filed by the assessee is allowed on this issue

ITA 1333/KOL/2025[2015-16]Status: DisposedITAT Kolkata04 Sept 2025AY 2015-16

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1333/Kol/2025 (निर्धारण वर्ा / Assessment Year : 2015-2016) Praveen Kumar Patwa Huf Vs Ito Ward-47 (2), Kolkata 12, Haradutta Ray Chamaria Rd Howrah, West Bengal-711101 Pan No. :Aajhp 7673 K (अपीलधर्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्धाररती की ओर से /Assessee By Shri Anil Kochar, Advocate रधजस्व की ओर से /Revenue By : Shri S.B.Chakraborthy, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 01/09/2025 घोषणा की तारीख/Date Of Pronouncement : 04/09/2025 आदेश / O R D E R Per Pradip Kumar Choubey, Jm : The Assessee Has Filed The Instant Appeal Against The Order Dated 23.05.2025, Passed By The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2015-2016. 2. The Sole Issue Involved In The Present Appeal Of The Assessee Is With Regard To Issuance Of Invalid Notice U/S.148 Of The Act Without Adhering To The New Inserted Provisions Of Section 148 R.W.S.148A Of The Act. 3. Ld. Ar Before Us Submitted That In This Case The Ao Has Framed The Assessment U/S.147 R.W.S.144 Of The Act Assessing The Total Income Of The Assessee At Rs.59,77,593/- Thereby Making Addition U/S.68 Of The Act At Rs.36,09,222/- & Addition Made U/S.69C Of The Act At Rs.1,80,461/-. In Appeal, The Ld.Cit(A) Dismissed The Appeal Of The Assessee. It Has Also Been Submitted By The Ld.Ar That Both The Authorities Below Have Erred In Not Considering The Fact That The Notice Issued U/S.148 Of The Act Is Invalid & Bad In Law As The Notice In This Case Has Been Issued On 01.04.2021

For Respondent: Shri S.B.Chakraborthy, Sr. DR

Section 147Section 148Section 148ASection 68Section 69C

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

M/S. Hydro Bs India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bengaluru

The appeal of the assessee is partly allowed

ITA 2117/BANG/2024[2020-21]Status: DisposedITAT Bangalore04 Sept 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Shri Harsha, CAFor Respondent: Dr. Divya K J, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144CSection 92CSection 92C(3)(c)

proposing adjustment of Rs.2,27,76,555. 2. The assessee is aggrieved and in appeal before us raising the following grounds :- “1. The Final Assessment order of the DCIT-3(1)(1) is not justified in law and on the facts and circumstances of the case. 2. The Directions ... companies which were examined and order giving effect was passed. Based on this, a shortfall was computed at Rs.1,46,70,674/-. Accordingly final assessment order was passed on 23.7.2024 incorporating the above adjustment. This order is appealed against. 11. In the appeal of the assessee, the ld. AR submitted

Zubin Jehanbux Gandevia, Mumbai vs. Income Tax Officer Int Tax Ward 2(3)(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 1789/MUM/2025[2022-23]Status: DisposedITAT Mumbai04 Sept 2025AY 2022-23

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Gunjan KakkadFor Respondent: Shri Krishna Kumar (SR DR)

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

02/09/2025 Date of pronouncement : 04/09/2025 O R D E R Per Anikesh Banerjee (JM): This appeal of the assessee is directed against the final assessment order of the passed by the Learned Income-tax Officer, Int. Tax Ward 2(3)(1), Mumbai, (in short, ‘Ld.AO’) order passed under section ... assessee at the assessment stage. So, the Ld.DRP rejected the assessee’s claim and upheld the impugned draft assessment order. Thereafter, the final assessment order was passed as per the recommendation of the Ld.DRP. 3. The Ld.AR filed a paper book containing pages 1 to 172, which is placed

Syntel Solutions (India) P. Ltd, Pune vs. Asst CIT Cir 10, Pune

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

ITA 1882/MUM/2017[2012-13]Status: DisposedITAT Mumbai04 Sept 2025AY 2012-13

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalsyntel Solutions (India) Pvt. Ltd., Ground Floor S2 Software, Block Plot No. B-1/B-2, Dehu Alandi Road Midc, Talwadi, Software Technology Park ............... Appellant Pune - 412114 Pan: Aadct5744N V/S

For Appellant: NoneFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(3)

Order - 04/09/2025 O R D E R PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeal challenging the impugned final assessment order dated 05/01/2017, passed under section 143(3) r.w.s 144C(13) of the Income-tax Act, 1961 (“the Act”), pursuant to the directions dated 21/12/2016 issued

Munich Re Automation Solutions Limited, Ireland vs. Assistant Commissioner of Income Tax, Circle International Tax, 2(2)(1), New Delhi

In the result, appeal of the assessee is partly allowed

ITA 3766/DEL/2023[2021-22]Status: DisposedITAT Delhi04 Sept 2025AY 2021-22

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.3766/िद"ी/2023(िन.व. 2021-22) Munich Re Automation Solutions Ltd., 2Nd Floor, Mountain View, Central Park, Leopardstown Office Park, Dublin, Ireland ...... अपीलाथ"/Appellant Pan : Aaicm-2594-E बनाम Vs. Assistant Commissioner Of Income Tax, ..... "ितवादी/Respondent Circle International Tax-2(2)(1), New Delhi अपीलाथ" "ारा/ Appellant By : Shri Vishal Kalra, Ms. Reema Grewal & Ms. Snigdha Gautam, Advocates "ितवादी"ारा/Respondent By : Ms. Ekta Jain, Cit-Dr & Ms. Neeju Gupta, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 06/06/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 04/09/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 25.10.2023 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Ay 2021-22. 2. Shri Vishal Kalra, Advocate Appearing On Behalf Of The Assessee At The Outset Submitted That He Is Not Pressing Ground No. 2 Of Appeal Challenging Validity Of Assessment Order On The Ground Of Limitation.

For Appellant: Shri Vishal Kalra, Ms. Reema Grewal, and Ms. Snigdha Gautam, AdvocatesFor Respondent: Ms. Ekta Jain, CIT-DR &

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

appeal, the ld. Counsel submits that without prejudice to the submissions on ground no. 3 and 4, the assessee has assailed final assessment order as the AO has erred in not following the directions of the DRP to allow credit of equalization levy paid at 2% against the Income ... directions of the DRP and prayed 5 for dismissing appeal of the assessee. The ld. DR referring to para 7 of the final assessment order submits that the AO has distinguished and demonstrated that the case of assessee does not fall within any of the four categories specified

Microsoft Corporation (India) Pvt Ltd, Delhi vs. DCIT (16) (1) Delhi, Delhi

Appeal of the assessee is allowed

ITA 1862/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Sept 2025AY 2017-18

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Vikas Awasthy & Shri Brajesh Kumar Singhआअसं.1862/िद"ी/2022 (िन.व. 2017-18) Microsoft Corporation (India) P. Ltd., 807, New Delhi House, Barakhamba Road, New Delhi 110001 ...... अपीलाथ"/Appellant Pan: Aaacm-5586-C बनाम Vs. Deputy Commissioner Of Income-Tax, Circle 16(1), Central Revenue Building, ..... "ितवादी/Respondent Ip Estate, Delhi अपीलाथ" "ारा/ Appellant By : S/Shri Nageswar Rao, (Through Vc) & Parth, Advocates "ितवादी"ारा/Respondent By : Shri Rajesh Kumar, Cit- Dr सुनवाई क" ितिथ/ Date Of Hearing : 04/09/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 04/09/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 30.06.2022, Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961, (Hereinafter Referred To As ‘The Act’) For Assessment Year 2017-18. 2. Shri Nageswar Rao, Appearing On Behalf Of The Assessee Submitted At The Outset That, At This Stage He Is Confining His Submissions To Ground No. 1 Of Appeal

For Appellant: S/Shri Nageswar Rao, (Through VC) &For Respondent: Shri Rajesh Kumar, CIT- DR

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

outset that, at this stage he is confining his submissions to ground no. 1 of appeal 2 only, assailing validity of final assessment order dated 30.06.2022 on the ground of limitation. 3. The ld. Counsel narrating relevant facts to the issue raised in ground no. 1 of appeal submits that ... Dispute Resolution Panel (DRP) issued directions u/s. 144C(5) of the Act on 23.03.2022, the Assessing Officer (AO) passed final assessment order on 23.06.2022. As per the provisions of Section 144C(13) of the Act, the AO is required to pass final assessment order within one month from

Hitachi Astemo Haryana Private Limited, Faridabad vs. Assistant Commissioner of Income Tax, Delhi

In the result, the Appeal of the Assessee is allowed

ITA 3353/DEL/2024[AY 2018-19]Status: DisposedITAT Delhi03 Sept 2025

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Hitachi Astemo Haryana Private Vs Assistant Commissioner Limited Of Income Tax, Circle Plot No. 23-32, Sector-58, 10(1), C. R. Building, Behind Jcb India Ltd, Ito, Ip Estate, Faridabad, Haryana, India New Delhi Pan: Aabce5725G Appellant Respondent Assessee By Ms. Ananya Kapoor, Adv Revenue By Sh. S. K. Jadhav, Cit- Dr Date Of Hearing 06/08/2025 Date Of Pronouncement 03 /09/2025 Order Per Yogesh Kumar, U.S. Jm: This Appeal Is Filed By The Assessee Pertaining To Assessment

Section 143(3)Section 144C(13)Section 153(5)Section 254Section 270ASection 92C

/09/2025 ORDER PER YOGESH KUMAR, U.S. JM: This appeal is filed by the assessee pertaining to Assessment Year 2018-19 challenging the Final Assessment Order passed by Assistant Commissioner of Income Tax, Circle -10(1)-Delhi dated 23/05/2024 u/s 143(3) r.w. Section 254 of the Income ... prejudice to other grounds, the Ld. AO has erred in incorrectly computing a tax demand of INR 1,38,22,160 in the final assessment order by not allowing set off of brought forward losses and unabsorbed depreciation. GROUNDS PERTAINING TO PAYMENT OF ROYALTY 3. Without prejudice