“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

Sfdc Ireland Limited, Delhi vs. Deputy Commissioner of Income-Tax- 3(1)(1) Intl Tax, Delhi

In the result, the appeal of assessee is allowed as above

ITA 1475/DEL/2025[2022-23]Status: DisposedITAT Delhi02 Sept 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

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

assessee filed this appeal raising following grounds: “1. On the facts and in the circumstances of the case and in law, the impugned final assessment order dated 27 January 2025 passed under section 143(3) read with section 144C(13) of the Income ... liable to be quashed. 1.1 On the facts and in the circumstances of the case and in law, the impugned final assessment order passed by the Ld. AO and the directions issued by the Ld. DRP are without jurisdiction, invalid and bad in law, as the same have been passed

M/S.Apollo Tyres Ltd, Cochin vs. The Principal Commissioner of Incometax, Cochin

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

ITA 609/COCH/2017[2013-14]Status: DisposedITAT Cochin01 Sept 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2013-14 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Dcit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 01.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 115JSection 143(3)Section 32Section 32(1)(iia)Section 35Section 43(1)Section 92C

Pronouncement: 01.09.2025 O R D E R Per: Inturi Rama Rao, AM This appeal filed by the assessee is directed against the final assessment order dated 27.10.2017 passed u/s. 143(3) r.w.s. 144C of Income Tax Act, 1961 (hereinafter "the Act") for Assessment Year (AY) 2013-14. 2. Brief facts ... determining the tax liability u/s. 115JB of the Act. 5. On receipt of the directions from the DRP, the AO had passed the final assessment order dated 27.10.2017 passed u/s. 143(3) r.w.s. 144C of the Act at a total income of Rs. 306,07,39,110/- after making

H. Srinivas Reddy, Bengaluru vs. ACIT, Central Circle-1(2), Bengaluru

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

ITA 629/BANG/2025[2016-17]Status: DisposedITAT Bangalore01 Sept 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Hemasundar P, CAFor Respondent: Shri Muthu Shankar, CIT-DR

Section 132Section 142(1)Section 143(3)Section 153ASection 153B

while earlier statutory notices under section 142(1) and notices of attachment under section 226 were properly sent to the correct address, the final assessment orders, demand notices, and penalty notices were suddenly sent to an alien address at “Flat No. 603, Athens, Prestige Properties, Koramangala, Bangalore – 560034,” which

H. Srinivas Reddy, Bengaluru vs. ACIT, Central Circle-1(2), Bengaluru

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

ITA 628/BANG/2025[2015-16]Status: DisposedITAT Bangalore01 Sept 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Hemasundar P, CAFor Respondent: Shri Muthu Shankar, CIT-DR

Section 132Section 142(1)Section 143(3)Section 153ASection 153B

H. Srinivas Reddy, Bengaluru vs. ACIT, Central Circle-1(2), Bengaluru

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

ITA 626/BANG/2025[2013-14]Status: DisposedITAT Bangalore01 Sept 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Hemasundar P, CAFor Respondent: Shri Muthu Shankar, CIT-DR

Section 132Section 142(1)Section 143(3)Section 153ASection 153B

H Srinivas Reddy, Bengaluru vs. ACIT, Central Circle-1(2), Bengaluru

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

ITA 623/BANG/2025[2010-11]Status: DisposedITAT Bangalore01 Sept 2025AY 2010-11

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Hemasundar P, CAFor Respondent: Shri Muthu Shankar, CIT-DR

Section 132Section 142(1)Section 143(3)Section 153ASection 153B

Masilamani Kavitha, Rep. by Masilamani, Chennai vs. ITO, Intl Taxation Ward-1(2), Chennai

In the result, the appeal filed by the assessee is dismissed as non-maintainable

ITA 1748/CHNY/2025[2020-21]Status: DisposedITAT Chennai29 Aug 2025AY 2020-21

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.1748/ Chny/2025 िनधा"रण वष" /Assessment Year: 2020-21

For Appellant: Shri K.Meenakshi Sundaram, ITPFor Respondent: Mrs. R. Anitha, Addl. CIT

Section 144C(1)Section 144C(2)Section 144C(3)Section 147

having filed objections before the DRP within the stipulated period prescribed u/s. 144C(2) of the Act. Consequently, the A.O. passed the final assessment order u/s. 144C(3) r.w.s 147 of the Act making an addition of Rs.6,00,000/-. Aggrieved, the assessee has filed the present appeal against

Taran Pal Wadhwan, Delhi vs. ACIT CC- 8, Delhi

In the result, both the appeals of the assessee are allowed

ITA 2688/DEL/2025[2019-20]Status: DisposedITAT Delhi29 Aug 2025AY 2019-20

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

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Mahesh Kumar, CIT(DR)

Section 153CSection 153D

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

Taran Pal Wadhwan, Delhi vs. ACIT CC 8, Delhi

In the result, both the appeals of the assessee are allowed

ITA 2687/DEL/2025[2018-19]Status: DisposedITAT Delhi29 Aug 2025AY 2018-19

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

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Mahesh Kumar, CIT(DR)

Section 153CSection 153D

Ceva Logistics India Private Limited, Mumbai vs. DCIT, 1(1), Gurgaon

In the result, Appeal of the Assessee is partly allowed

ITA 4194/DEL/2024[2020-21]Status: DisposedITAT Delhi29 Aug 2025AY 2020-21

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ceva Logistics India Private Vs Deputy Commissioner Of Limited Income Tax-1(1) The Qube-A-902/903, 9Th National E-Assessment Floor, M.V. Road, Marol, Centre-Gurgaon, Andheri East Mumbai, Haryana Maharashtra, 400059 Pan: Aabct7326A Appellant Respondent Assessee By Ms. Ananya Kapoor, Adv& Sh. Bhavesh Mehta, Ca Revenue By Sh. S. K. Jadhav, Cit-Dr Date Of Hearing 06/08/2025 Date Of Pronouncement 29/08/2025 Order Per Yogesh Kumar, U.S. Jm: This Appeal Is Filed By The Assesseepertaining To Assessment Year 2020-21 Challenging The Final Assessment Order Passed By Deputy Commissioner Of Income Tax, Circle -1(1) Dated 15/07/2024 U/S143(3) R.W. Section 144C(13) Read With Section 144B Of The Income Tax Act, 1961 ('Act' For Short).

Section 139(5)Section 143(3)Section 144BSection 144C(13)

Pronouncement 29/08/2025 ORDER PER YOGESH KUMAR, U.S. JM: This appeal is filed by the assesseepertaining to Assessment Year 2020-21 challenging the Final Assessment Order passed by Deputy Commissioner of Income Tax, Circle -1(1) dated 15/07/2024 u/s143(3) r.w. Section 144C(13) read with Section 144B of the Income ... erred in completing the assessment proceedings based on the standalone return filed by the Assessee. The Ld. A.O, while passing the Final assessment Order, failed to consider the Assessee’s request 2 Ceva Logistics India Pvt. Ltd. Vs. DCIT to keep the proceedings on hold as the Assessee

Richemont India Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, Circle 19(1), New Delhi

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

ITA 3688/DEL/2024[2020-21]Status: DisposedITAT Delhi29 Aug 2025AY 2020-21

Bench: Shri Sudhir Pareek & Shri Manish Agarwalrichemont India Private Dy. Cit, Limited, Circle-19(1), Unit No.6B, 6Th Floor, Aria Vs. New Delhi. Tower, Hotel J.W. Mariott, Aerocity Asset Area-4, Hospitality District, Delhi-110037. Pan-Aadcr9256R (Appellant) (Respondent) Assessee By Ms. Reema Malik, Adv. Department By Shri Dharm Veer Singh, Cit-Dr Date Of Hearing 28/08/2025 Date Of Pronouncement 28/08/2025 O R D E R [ Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Assessment Order Dated 18.06.2024 Passed By The Income Tax Officer In Compliance To The Direction Given By The Drp.

Section 144C(5)

therefore, necessary directions be given to the AO for taking the said order on record as the AO has passed the final assessment order without considering the aforesaid order of the TPO dated 18.06.2024. 3. On the other hand, the Ld. CIT-DR stated that it is a factual aspect ... find that TPO finally computed transfer price adjustments at Nil and the AO has not considered this order of TPO while passing the final assessment order on very same day i.e. on 18.06.2024, against which the assessee is in appeal before us. 5. In view of these facts, we hereby

Ananda Gorakhanath Pawar, Satara vs. Assessing Officer, Ward 3, Satara

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

ITA 1796/PUN/2025[2018-19]Status: DisposedITAT Pune28 Aug 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1796/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Ananda Gorakhanath Pawar, Vs. Ito, Ward-3, Satara. At Post Ambawade, Khatav, Satara- 415506. Pan : Blhpp6081R Appellant Respondent Assessee By Shri R. C. Doshi : Revenue By : Shri Milind Debaje Date Of Hearing : 28.08.2025 Date Of Pronouncement : 28.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.06.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Filed The Following Grounds Of Appeal :- “1. The Learned Cit Has Erred Both On Facts & In Law In Dismissing The Appeal Of The Appellant By Refusing To Condone The Delay Of 26 Days On Grounds Of Period Of Limitation, Notwithstanding The Fact That Appellant Has Submitted The Application & Explained The Reasons For Delay.

For Respondent: Shri Milind Debaje

Section 143(2)Section 144BSection 147Section 148Section 148ASection 151ASection 184ASection 4

facts, circumstances of the case and in law and by not following the procedure given in section 144B while passing the final assessment order and by not issuing show cause notice before making following addition / disallowance: • Disallowed purchase of milk amounting to INR 5,34,649 • Disallowed payment made ... follow the procedure given under section 144B that draft order should be passed by learned AO under section 144B before passing final assessment order. The learned AO without passing draft order under section 144B, directly passed final order under section 147. Though the learned AO passed a draft order under

Accenture Solutions Private Limited, Mumbai vs. Dy. Commissioner of Income Tax, Mumbai

In the result, the appeal is allowed as indicated above

ITA 3457/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Aug 2025AY 2017-18

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am Accenture Solutions Private Limited Pr. Cit, 501, 5Th Floor, Plat 3, Godrej & Boycee Compound, Vikhroli (W), Vikhroli S.O., Vs. Aayakar Bhavan, M. K. Road, Mumbai-400 079 Mumbai-400 020 Pan/Gir No. (Appellant) : (Respondent) Appellant By : Shri Nishant Thakkar Respondent By : Shri Satya Pal Kumar Date Of Hearing : 18.08.2025 Date Of Pronouncement : 28.08.2025 O R D E R Per Saktijit Dey, Vp: The Captioned Appeal Has Been Filed By The Assessee, Assailing The Order Dated 20.03.2025, Passed U/S. 263 Of Income Tax Act, 1961 (‘The Act’ For Short) By Learned Principal Commissioner Of Income Tax, Mumbai-6 (‘Ld. Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2017-18. 2. We Have Heard The Parties & Perused The Materials Available On Record. The Short Issue Arising For Consideration Is Whether The Final Assessment Order Passed U/S. 144C(13) Of The Act, Can Be Subjected To Revisionary Jurisdiction U/S. 263 Of The Act. For Deciding This Issue, Few Necessary Facts Are Required To Be Considered. The Assessee Is A Resident Corporate Entity Engaged In The Business Of Providing Information Technology (It)/Information Technology Enabled Service (Ites) To Its Group Companies As Well As Consulting Services To Its Clients. For The Assessment Year Under Dispute, The Assessee Filed

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Satya Pal Kumar

Section 143(3)Section 144C(13)Section 263Section 80G

have heard the parties and perused the materials available on record. The short issue arising for consideration is whether the final assessment order passed u/s. 144C(13) of the Act, can be subjected to revisionary jurisdiction u/s. 263 of the Act. For deciding this issue, few necessary facts are required ... made in the order passed u/s. 263 of the Act. 5. Before us, ld. Counsel appearing for the assessee submitted that against the final assessment order passed in pursuance to directions of DRP, the revisionary authority cannot assume jurisdiction u/s. 263 of the Act. He submitted, the issue

Garware Fulflex India Pvt Ltd, Mumbai vs. DCIT, Circle 1(1)(1), Mumbai

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

ITA 6751/MUM/2024[2021-22]Status: DisposedITAT Mumbai28 Aug 2025AY 2021-22

Bench: Smt. Beena Pillai () & Shri Om Prakash Kant ()

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

Chinmay Nagwat : Mr. Bhagirath Ramawat, Sr. DR : 10/06/2025 : 28/08/2025 ORDER PER OM PRAKASH KANT, AM This appeal by the assessee is directed against final assessment order dated 28.10.2024 passed by the Ld. Dy. Commissioner of Income-tax, Circle 1(1)(1), Mumbai (hereinafter shall be referred as ‘Assessing Officer ... case and in law, the Hon'ble DRP and consequentially, the learned TPO and learned AO have: I. Legal Ground of Appeal 1. Final Assessment order is time barred Erred in passing final assessment order under section 143(3) read with section 144C(13) of the Act ('Final Assessment Order

Elentee Co. Ltd., Korea vs. DCIT, International Taxation, Noida

In the result, Appeal of the Assessee is partly allowed

ITA 972/DEL/2025[2022-23]Status: DisposedITAT Delhi28 Aug 2025AY 2022-23

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Eleentec Co. Ld. Vs. Deputy/Assistant 37 Samsung-Ro268 Beon-Gil Director Of Income Tax, Yeongtong-Gu, Gyeonggi Do International Taxation, Republic Of Korea Noida, Uttar Pradesh Pan: Aafce6530P Appellant Respondent Assessee By Sh. Himanshu S. Sinha, Adv, Sh. Prashant Mehar Chandani, Adv& Sh. Jainender Singh Kataria, Adv Revenue By Sh. M.S. Nethrapal, Cit Dr Date Of Hearing 19/08/2025 Date Of Pronouncement 28/08/2025

Section 143(3)Section 144C(13)Section 153(1)

Pronouncement 28/08/2025 ORDER PER YOGESH KUMAR, U.S. JM: This appeal is filed by the assessee pertaining to Assessment Year 2022-23 challenging the Final Assessment Order passed by Deputy Commissioner of Income Tax DDIT/ADIT, International Taxation, Nodia dated 20/01/2025 u/s143(3) r.w. Section 144C(13) of the Income ... order dated 20/12/2024, upheld the findings of the A.O. made in the draft assessment order. Consequent to the order of the DRP, a final Assessment Order came to be passed on 20/01/2025u/s 143(3) r.w. Section 144C(13) of the Act, wherein the A.O. confirmed the addition

M/S Takata India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

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

ITA 6835/DEL/2015[2011-12]Status: DisposedITAT Delhi28 Aug 2025AY 2011-12

Bench: Shri Prakash Chand Yadav & Manish Agarwalassessment Year: 2011-12 Takata India Pvt Ltd., Vs. Dcit, Circle 25(1), (Now Joyson Anand Abhishek New Delhi Safety Systems Pvt Ltd.,) Plot No.20, Sector-5, Imt Manesar, Gurugram (Haryana)-122050 Pan/Gir No. Aacct 7200 N (Appellant) .. ( Respondent)

For Appellant: NoneFor Respondent: Shri S.K.Jadhav, CIT (DR)

Length Price and revised the adjustment to the tune of Rs.11,89,11,663/-. Accordingly, the Assessing Officer passed the final assessment order, which is impugned before us. . ITA No.6835/Del2015 Assessment Year: 2011-12 Page 5 of 9 6. It is also pertinent to note that in this case

Vishno Motwani, Ajmer vs. Circle(Inttax), Jaipur

Appeal is hereby allowed and the impugned order dated 25

ITA 455/JPR/2024[2015-16]Status: DisposedITAT Jaipur27 Aug 2025AY 2015-16

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Satish Shivnai, C.AFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 142(1)Section 144Section 144C(1)Section 148Section 156Section 195Section 271(1)(b)Section 271(1)(c)Section 69

Notice u/s 156 of the Act & Penalty notice u/s 271(1)(c) and 271F of the Act to be issued along with the final assessment order. Penalty u/s 271(1)(b) of the I.T. Act, 1961 to be initiated separately for non- compliance of the notice

ACIT., Circle-1, Nellor vs. Zuari Cement Limited, Kadapa

In the result, the appeal of the Revenue is dismissed

ITA 927/HYD/2025[2010-11]Status: DisposedITAT Hyderabad26 Aug 2025AY 2010-11

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Nitin Narang, C.AFor Respondent: Dr. Narendra Kumar Naik

Section 143(3)Section 144CSection 144C(1)Section 144C(13)Section 254

income at Rs.252,54,44,320/-, in pursuance of the ITA No.927/Hyd/2025 4 directions of the Learned Dispute Resolution Panel ( “Ld.DRP”). Against the final assessment order of the Ld. AO, the assessee preferred an appeal before the Tribunal. Vide order dated 05.08.2016, this Tribunal set aside the assessment ... order wherein the legal ground of the assessee was allowed. He submitted that in the first round of proceedings, the original final assessment order was passed under section 143(3) read with section 144C(13) of the Act in conformity with the Ld. DRP’s directions, after issuance

Panda Srinivas, Hyderabad vs. ADIT (Int Taxn)-2, Hyderabad

ITA 682/HYD/2025[2018-19]Status: DisposedITAT Hyderabad26 Aug 2025AY 2018-19

Bench: Us:

Section 143(2)Section 144C(1)Section 144C(5)Section 147Section 148Section 148ASection 54F

dated 26.11.2024. 6. Thereafter, the A.O. after receiving the order passed by the DRP-1, Bengaluru, dated 26.11.2024 passed the final assessment order u/s 147 r.w.s. 144C(13) of the Act, dated 21.12.2024 wherein the income of the assessee was assessed at Rs.2,68,50,592/-. 7. The assessee assailed ... mandate of law. However, no contention was advanced regarding the observation of the CIT(A) that the appeal against the final assessment order passed u/s 147 r.w.s. 144C(13) of the Act, dated 21.12.2024 based on the directions of the DRP-1, Bengaluru was not maintainable before

Pioneer Hi-Bred Private Limited, Hyderabad vs. DCIT., Circle 5(1), Hyderabad

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

ITA 1206/HYD/2024[2021-22]Status: DisposedITAT Hyderabad26 Aug 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1206/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2021-22) M/S. Pioneer Hi-Bred Private Dy. Commissioner Of Income Tax, Vs. Circle 5(1), Hyderabad. Limited, Hyderabad. Pan: Aahcp6154C (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Deepak Chopra & Ashmita Sharma, Advocates. रधजस् व द्वधरध/Revenue By: Dr. Narendra Kumar Naik,Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 20/08/2025 घोर्णध की तधरीख/Pronouncement: 26/08/2025 आदेश/Order Per Madhusudan Sawdia, A.M. : This Appeal Is Filed By M/S. Pioneer Hi-Bred Private Limited (“The Assessee”), Feeling Aggrieved By The Final Assessment Order Passed By The Learned Assessing Officer (“Ld. Ao”) U/S. 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (“The Act”) Dated 24.10.2024 For The A.Y. 2021-22. 2. The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri Deepak Chopra & AshmitaFor Respondent: Dr. Narendra Kumar Naik,CIT-DR

Section 143(3)Section 271A

आदेश/ORDER PER MADHUSUDAN SAWDIA, A.M. : This appeal is filed by M/s. Pioneer Hi-Bred Private Limited (“the assessee”), feeling aggrieved by the final assessment order passed by the Learned Assessing Officer (“Ld. AO”) u/s. 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income ... account of provision of R & D services, computing the total income at Rs.37,76,03,627/-. 5. Aggrieved with the final assessment order of Ld. AO, the assessee is in appeal before us. At the outset, the Learned Authorised Representative (“Ld. AR”) submitted that ground no.1 is general in nature