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“final assessment order”

Assessment ProceduresSection 144CSection 144C4,041 judgments

The decision most relied on for final assessment order is Parashuram Pottery Works Co. Ltd. v. ITO (106 ITR 1), cited in 486 judgments on BharatTax.

Leading authorities on final assessment order

Parashuram Pottery Works Co. Ltd. v. ITO
106 ITR 1 · 1977 · Supreme Court
486
citing judgments

The principle of finality dictates that stale issues should not be reactivated, and lapse of time brings repose to judicial and quasi-judicial controversies. A Commissioner cannot substitute their judgment for the Assessing Officer's unless the assessment order is legally erroneous, not merely less elaborate, thus limiting revisionary powers under Section 263.

Commissioner of Income Tax v. Roca Bathroom Products (P) ltd.
445 ITR 537 · 2022 · High Court
269
citing judgments

The time limit for the Assessing Officer to pass a final assessment order under Section 144C(13) following directions from the Dispute Resolution Panel is determined by the specific provisions of Section 153, particularly Section 153(2A).

CIT v. G.M. Knitting Industries (P.) Ltd.
376 ITR 456 · 2015 · Supreme Court
221
citing judgments

The requirement to file a certificate or form (e.g., Form 10CCB, 10-IC) along with the return of income for claiming a deduction (e.g., under sections 80-IB, 115BAA) is directory regarding its timing. Such a deduction is allowable if the requisite form is filed before the final order of assessment, as procedural requirements should not override substantive benefits.

Sultana Begum v. Prem Chand Jain
259 ITR 449 · 2003 · Supreme Court
147
citing judgments

Section 144C(4) uses a non-obstante clause to expedite the final assessment order, requiring the Assessing Officer to pass it immediately upon acceptance or lack of objection to the TPO's order, irrespective of broader time limits under Section 153.

Vijay Television (P.) Ltd. v. DRP
369 ITR 113 · 2014 · High Court
140
citing judgments

Passing a final assessment order under Section 143(3) directly, without first issuing a draft assessment order under Section 144C(1) for an eligible assessee, constitutes a fundamental jurisdictional defect. This defect cannot be cured by a subsequent corrigendum, especially if issued beyond the prescribed period of limitation.

ESPN Star Sports Mauritius S.N.C. ET Compagnie v. Union of India
388 ITR 383 · 2016 · High Court
71
citing judgments

Failure to issue a draft assessment order under Section 144C(1) makes the final assessment order illegal and beyond jurisdiction. Non-compliance with Dispute Resolution Panel (DRP) directions renders the final assessment order bad in law.

Travancore Diagnostics P. Ltd. v. ACIT
390 ITR 167 · 2017 · High Court
50
citing judgments

Failure to issue notice under section 143(2) before finalizing a reassessment order under section 147 is a fatal jurisdictional error, and this defect cannot be cured by invoking section 292BB of the Income-tax Act. Consequently, such a reassessment order is not sustainable in law.

Addl. CIT v. Mukur Corporation
111 ITR 312 · 1978 · High Court
49
citing judgments

When setting aside an assessment under Section 263(1) and directing a fresh assessment, the Commissioner need not record final conclusions or express final opinions on controversial points. It also interprets 'prejudicial to the interests of the Revenue' as meaning the assessment order is not in accordance with law, leading to the non-realization of lawful revenue.

Judgments citing final assessment order

Mondelez India Foods Pvt. Ltd. (Formerly Known As Cadbury India Ltd.), Mumbai vs. ACIT, Range 5 (1)(2), Mumbai

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

ITA 7269/MUM/2019[2015-16]Status: DisposedITAT Mumbai22 Aug 2025AY 2015-16

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.7269/Mum/2019 निर्धारण वर्ष / Assessment Year :2015-16 M/S Mondelez India Foods Private Limited (Formerly Known As Cadbury India Limited), Mondelez House, Unit No.2001, 20Th Floor Tower-3 (Wing C) India Bulls Finance Centre), Parel, Mumbai-400 013 Pan : Aaac0460H ........अपीलार्थी / Appellant बनाम / V/S. The Assistant Commissioner Of Income-Tax, Range-5(1)(2), Mumbai, Aayakar Bhavan, M.K. Road Mumbai-400 020 ......प्रत्यर्थी / Respondent Assessee By : Shri J.D. Mistri, Sr. Advocate Shri Hiten Chande Revenue By : Shri Pankaj Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing :18.08.2025 घोषणा की तारीख / Date Of Pronouncement : 22.08.2025

For Appellant: Shri J.D. Mistri, Sr. AdvocateFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 115JSection 143(3)Section 144C(1)Section 144C(5)Section 14ASection 234C

before the DRP. The DRPconfirmed the adjustments/disallowances made by the TPO/Assessing Officer. The assessee, therefore, is in appeal before the Tribunal against the final assessment order passed by the Assessing Officer dated 31.10.2019 pursuant to theDRP directions dated 23.09.2019. 7. The Ld. Counsel for the assessee during the course ... aforesaid view of Tribunal in assessee's own case, we delete the impugned adjustment of Rs.1300.22 Lacs asmade by Ld. AO in the final assessment order. Nothing has been shown to us thatthe aforesaid ruling is not applicable to the year under consideration. Ground No.3stand allowed. With regard to disallowance

Bain and Company, Usa vs. DCIT, Gurgoan

In the result, appeal of assessee in ITA Nos

ITA 3056/DEL/2023[2021-22]Status: DisposedITAT Delhi22 Aug 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Ms. Ekta Jain, CIT- DR
Section 143(3)

Assessing Officer ('AO') erred on facts and in law in assessing the income of the Appellant at Rs. 144,48,50,120/- vide Final Assessment Order dated 31 March 2023 as against the returned income of Rs.27,57,87,110/- declared by the Appellant. GROUNDS PERTAINING TO MANAGEMENT CONSULTING SERVICES

Veritas Storage (Singapore) Pte. Ltd, Singapore vs. DCIT, Circle 3(1)(1), International Taxation, New Delhi

In the result, appeal of assessee in ITA No

ITA 1913/DEL/2023[2020-21]Status: DisposedITAT Delhi22 Aug 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Naveen Chandra

For Appellant: Shri Tarun Gulati, Sr. AdvFor Respondent: Shri Vedanshu Tripathi, CIT- DR
Section 143(3)

satisfied. Appeal of the assessee on Ground Nos. 4 and 5 are allowed." 8. On perusal of the draft assessment order and the final assessment order, we note that during the present assessment year i.e. AY 2020-21, the Assessing Officer has accepted the claim of the assessee that

Bain & Company, Inc., Usa vs. DCIT Intl. Taxation Circle, New Delhi

In the result, appeal of assessee in ITA Nos

ITA 1677/DEL/2023[2020-21]Status: DisposedITAT Delhi22 Aug 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Ms. Ekta Jain, CIT- DR
Section 143(3)

Assessing Officer ('AO') erred on facts and in law in assessing the income of the Appellant at Rs. 144,48,50,120/- vide Final Assessment Order dated 31 March 2023 as against the returned income of Rs.27,57,87,110/- declared by the Appellant. GROUNDS PERTAINING TO MANAGEMENT CONSULTING SERVICES

Stryker India Private Limited, New Delhi vs. ACIT, Circle-22(2), New Delhi

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

ITA 2449/DEL/2022[2018-19]Status: DisposedITAT Delhi22 Aug 2025AY 2018-19

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalstryker India Private Limited Assistant Commissioner C-5, Sda Commercial Complex, Of Income Tax, New Delhi-110016. Vs. Circle-22(2), New Delhi. Pan-Aaecs2513F (Appellant) (Respondent)

Section 92C

final set off comparables and the Ld. DRP sustained the other adjustments qua interest on outstanding receivables. Thereafter, the AO passed the final assessment order. 4. Aggrieved with the order of AO, the assessee has come up in appeal and has raised the following grounds of appeal

Prithvi Information Solutions Limited, Hyderabad vs. ACIT, Circle-16(2), Hyderabad

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

ITA 47/HYD/2017[2010-11]Status: DisposedITAT Hyderabad20 Aug 2025AY 2010-11

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali MohanRao, C.AFor Respondent: Shri Narender Kumar Naik
Section 143(3)

High Court passed an order for liquidation of the company on 27.01.2015 (page nos.110 to 112 of the paper book). The final assessment order was thereafter passed by the Ld. AO on 26.02.2015, i.e., after the order of the Hon’ble High Court for liquidation. In accordance with ... section 144C of the Act, upon receipt of the directions u/s 144C(5) of the act the assessing officer should pass the relevant final assessment order within one month from the end of the month in which such directions is received. 11. The Ld. AO ought to have appreciated that

Narayanan, Chromepet vs. Income Tax Officer, Chennai

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

ITA 695/CHNY/2025[2018-2019]Status: DisposedITAT Chennai20 Aug 2025AY 2018-2019

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.695/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Narayanan, Vs. The Income Tax Officer, F-1, 37/60, Guru Balaji Apts, International Taxation Ward 2(1), First Main Road, New Colony, Chennai. Chromepet, Chennai 600 044. [Pan:Ackpn6481A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 24.07.2025 घोषणा की तारीख /Date Of Pronouncement : 20.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Dated 06.01.2025 Passed By The Income Tax Officer, International Taxation Ward 2(1), Chennai Under Section 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 [“Act” In Short] For The Assessment Year 2018-19. 2. When The Appeal Was Taken Up For Hearing On 24.07.2025, We Find No Representation On Behalf Of The Assessee. However, We Find Paper

For Appellant: NoneFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 142(1)Section 143(2)Section 144C(1)Section 147Section 148Section 69

आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This appeal filed by the assessee is directed against the final assessment order dated 06.01.2025 passed by the Income Tax Officer, International Taxation Ward 2(1), Chennai under section 147 r.w.s. 144C(13) of the Income

Naval Kishor Mundra, Mumbai vs. Income Tax Officer-4(2)(1), Mumbai

In the result, the appeal is accordingly allowed for

ITA 4200/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Aug 2025AY 2015-16

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhan

Section 143(1)Section 143(3)Section 148Section 250Section 69

assumption and surmise basis without bringing any material against the appellant. c) Addition amount mentioned in Draft Assessment Order cannot be enhanced in final assessment order without issuing new draft assessment order with show cause notice. d) Nodefect in books of account was found, even no defect in document submitted ... assumption and surmise basis without bringing any material against the appellant. c) Addition amount mentioned in Draft Assessment Order cannot be enhanced in final assessment order without issuing new draft assessment order with show cause notice. d) No defect in books of account was found, even no defect in document

Khvatec India Private Limited, Gautam Buddha Nagar vs. Assessing Officer, Noida Up

In the result, appeal of the assessee is dismissed as withdrawn, as indicated above

ITA 5650/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Aug 2025AY 2021-22

Bench: Shri Sudhir Pareek & Shri Manish Agarwal

For Appellant: Shri Prem Lamba, CAFor Respondent: Shri Dharm Veer Singh, CIT(DR)
Section 143(3)Section 144C

Hearing : 20.08.2025 Date of Pronouncement : 20.08.2025 ORDER PER SUDHIR PAREEK, JM: The aforetitled appeal has been preferred by the assessee against the Final Assessment Order dated 28.09.20224 passed by the Learned Assessing Officer u/s 143(3) read with Section 144C (13) r.w.s. s. 144B of the Income

Indian Metals and Ferro Alloys Ltd, Bhubaneswar vs. DCIT, Circle-1(1), Bhubaneswar

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

ITA 506/CTK/2024[2021-22]Status: DisposedITAT Cuttack19 Aug 2025AY 2021-22

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 234BSection 234CSection 270ASection 92CSection 92D

appeal before the Tribunal raising the following grounds of appeal: “1. That on the facts and circumstances of the case & in law, the final assessment order dated October 28, 2024, passed by the National Faceless Assessment Centre, Assessment Unit, Income Tax Department (the Ld. AO), making an addition

M/S Gvk Jaipur Expressway Private Limited, Telangana vs. PCIT 2, Jaipur

In the result, the appeal of the assessee is allowed

ITA 248/JPR/2023[2018-19]Status: DisposedITAT Jaipur19 Aug 2025AY 2018-19
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115Section 115JSection 143(3)Section 14ASection 263Section 36(1)(iii)Section 80

draft assessment order. In reply to the same, assessee filed a detailed submission on 18.03.2021 (APB 95-111), and after considering the same, final assessment order was passed by making disallowance u/s 14A of Rs.89,42,24,331/- and the said amount was also included in the book profit ... disallowance u/s 14A at Rs. 92,98,58,499/-, as per para 3, page 2-3 of the draft assessment order. In the final assessment order, the AO has made disallowance of Rs. 89,42,24,331/- u/s 14A and said amount has also been included in the book profit

Chellappan Sankaranathan, Sivaganga vs. ACIT, International Taxation Circle, Madurai

In the result, appeal filed by the assessee is allowed in terms of our

ITA 930/CHNY/2025[2019-20]Status: DisposedITAT Chennai19 Aug 2025AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita No.930/2025 (िनधा(रणवष( / Assessment Year: 2019-20)

For Appellant: Mr.N.V. Narayanan, AdvocateFor Respondent: Ms.Anitha, Addl.CIT
Section 144BSection 147Section 148Section 148A

Pronouncement : 19.08.2025 आदेश / O R D E R MANU KUMAR GIRI (Judicial Member) This appeal by the assessee is arising out of the final assessment order dated 10.01.2025, passed by the Income Tax officer, Intl Taxn Circle MDU, for the assessment year 2019-20 u/s.147 r.w.s. 144C

Jaldhi Overseas Pte. Ltd., Singapore vs. ACIT/DCIT, International Taxation-1(2), Chennai

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

ITA 366/CHNY/2025[2022-23]Status: DisposedITAT Chennai19 Aug 2025AY 2022-23

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita No.366/Chny/2025 िनधा"रण वष"/Assessment Year: 2022-23 V. Jaldhi Overseas Pte. Ltd., The Assistant Commissioner Of #25-60, Tong Eng Building, 101, Cecil Income Tax, International Street, Singapore 069533. Taxation, Dcit, Intl. Tax 1(2), C/O. Bothra Shipping Services Private Chennai. Limited, Vasundhara, 9Th Floor, Unit-A, 2/7 Sarat Bose Road, L.R. Sarani S.O., Kalkata, West Bengal 700 020. [Pan: Aadcj0165F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri Ashik Shah, C.A. ""थ" की ओर से /Respondent By : Ms. E. Pavuna Sundari, Cit सुनवाईकीतारीख/Date Of Hearing : 13.08.2025 घोषणाकीतारीख /Date Of Pronouncement : 19.08.2025 आदेश / O R D E R Per Manu Kumar Giri, Jm:

For Appellant: Shri Ashik Shah, C.AFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143(2)Section 143(3)Section 144C(1)Section 144C(13)Section 153Section 44B

objections before the Dispute Resolution Panel (‘DRP’), which was disposed vide directions dated 29.11.2024 upholding the order of the Assessing Officer. Subsequently, the final assessment order dated 16.12.2024 was completed under section 143(3) r.w.s. 144C(13) of the Act against which the assessee is in appeal before the Tribunal ... such is liable to be quashed. 2. On the facts and in the circumstances of the case and in law, the final assessment order dated December 16, 2024 passed under section 143(3) read with section 144C(13) having been passed beyond the limitation provided in section 153, is barred

Suresh Kumar Mahavir Prasad Beswal, Thane vs. Assessment Unit, NFAC

The appeal of the assessee is allowed

ITA 5156/MUM/2024[2013-14]Status: DisposedITAT Mumbai19 Aug 2025AY 2013-14

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Piyush Chhajed, CAFor Respondent: Shri Swapnil Choudhary, Sr. DR
Section 147Section 148Section 148ASection 151Section 250Section 69A

section 148A(d) dated 10.07.2022 and the notice under section 148 dated 10.07.2022 are all are issued by the JAO and only the final assessment order dated 24.05.2023 is passed by the FAO. From the perusal of these facts, it is clear that the facts are similar to the facts

Te Connectivity Services India Private Limited, Bangalore vs. DCIT Circle, 7(1)(1), Bangalore

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

ITA 1887/BANG/2024[2020-21]Status: DisposedITAT Bangalore18 Aug 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: S/Shri Sriram Sheshadri & Vinay Jain, CAsFor Respondent: Smt. Suganthamala T M, CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 144CSection 40Section 92C

dated 10.7.2024, the TP adjustment to the extent of Rs.10,62,815 was retained. So far as Transfer pricing issues are concerned, in Final assessment order Transfer pricing adjustment of Rs.10,62,815 was retained. 6. The ld. AO during the course of assessment proceedings found that there are foreign

Rubicon Research Limited (Formerly Known As Rubicon Research Private Limited), Thane, Maharashtra vs. Deputy Commissioner of Income Tax - Circle 15(3)(1), Mumbai

In the result, assessee’s appeal is allowed for statistical purposes

ITA 6647/MUM/2024[2021-22]Status: DisposedITAT Mumbai18 Aug 2025AY 2021-22

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No.6647/Mum/2024 (निर्धारण वर्ा/Assessment Year: 2021-22) Rubicon Research V/S. Deputy Commissioner Of Limited (Formerly बिधम Income Tax- Circle Known As Rubicon 15(3)(1), Mumbai Research Private Aaykar Bhavan, Maharshi Limited) Karve Road, New Marine Medone House, B-75, Lines, Churchgate, Mumbai Road No. 33, Wagle 400020 Estate, Thane 400604. Assessment Unit, National Faceless Assessment Centre Income Tax Department, Ministry Of Finance Delhi स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcr1422M Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी निर्ााररती की ओर से /Assessee By: Shri. Darpan Kirpalani रधजस्व की ओर से /Revenue By: Shri. Asif Karmali (Sr Dr)

For Appellant: Shri. Darpan KirpalaniFor Respondent: Shri. Asif Karmali (SR DR)
Section 143(3)Section 153Section 234BSection 37Section 92CSection 92C(3)Section 92D

assessee has raised the following grounds of appeal: “1. On the facts and circumstances of the case and in law, the final assessment order dated 23 October 2024 is issued beyond the time limit as prescribed u/s 153 of the Act. Consequently, the final assessment order is time barred

Raj International Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle-4(3)(1), Mumbai

ITA 6286/MUM/2024[2014-15]Status: DisposedITAT Mumbai18 Aug 2025AY 2014-15

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri K. Gopal Adv. & Ms. Neha
Section 143(3)Section 147Section 148Section 151ASection 250Section 69A

accordingly the AO passed an order under section 148A(d) and the notice under section 148 on 27.07.2022. The AO passed the final assessment order on 29.05.2023 assessing the income of the assessee

Raj International Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle-4(3)(1), Mumbai

ITA 6285/MUM/2024[2013-14]Status: DisposedITAT Mumbai18 Aug 2025AY 2013-14

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri K. Gopal Adv. & Ms. Neha
Section 143(3)Section 147Section 148Section 151ASection 250Section 69A

accordingly the AO passed an order under section 148A(d) and the notice under section 148 on 27.07.2022. The AO passed the final assessment order on 29.05.2023 assessing the income of the assessee

Ravi Kumar, New Delhi vs. DCIT, Circle Int. Tax 2(1)(2), New Delhi

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

ITA 1783/DEL/2024[2017-18]Status: DisposedITAT Delhi18 Aug 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 144CSection 147Section 148Section 148ASection 68Section 8

Credits Private Ltd. are not with the AO and the Ld. DRP at the time of passing the final assessment order and issuing directions under section 144C(5) of the Act. 7. We find merit in the argument/contention/submission of the Ld. AR that the sum of Rs.1

Pratheush Antony Langbein, Mulavana House, Thuruthy P.O, Vazhappally West vs. DCIT Circle Intl.Txn, Tvm, Thiruvananthapuram

In the result, appeal filed by the appellant stands dismissed

ITA 507/COCH/2025[2018-2019]Status: DisposedITAT Cochin13 Aug 2025AY 2018-2019

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2018-19 Pratheush Antony Langbein, .......... Appellant Mulavana House, Thuruthy P.O., Vazhappally West, Kottayam, Kerala. [Pan: Avgpl 2952 D] Vs. Dy. Commissioner Of Income Tax .......... Respondent Circle International Taxation, Tvm Appellant By: Shri Tony C Kallukalam, Ca Respondent By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 05.08.2025 Date Of Pronouncement: 13.08.2025

For Appellant: Shri Tony C Kallukalam, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(1)Section 144C(1)Section 147Section 148Section 245M

Date of Hearing: 05.08.2025 Date of Pronouncement: 13.08.2025 O R D E R This appeal filed by the assessee is directed against the final assessment order dated 27.01.2025passed u/s. 147 r.w.s. 144C(13) of the Income Tax Act, 1961 for Assessment Year (AY) 2018-19. 2. Brief facts ... specified order’ as the aggregate sum of variation is more than the threshold limit of Rs. 10 lakh. Therefore, AO passed the final assessment order u/s. 147 r.w.s. 144C(13) of the Act dated 27/01/2025 assessing total income at Rs. 22,60,916/-. 3. Being aggrieved, the appellant