“final assessment order”

Genpact Services Llc, Gurgaon vs. Assistant Commissioner of Income Tax Circle - Int Tax 1(3)(1), Delhi

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

perusal of the TPO order u/s 92CA(3) of the Act dated 27.02.2023, the draft assessment order (hereinafter referred as DAO) and the final assessment order (hereinafter referred as FAO), we find that, the issues in question are identical to those of the preceding assessment years

Expedia Online Travel Services India Private Limited, New Delhi vs. Deputy Commissioner of Income Tax Circle 7(1), Cr Building Delhi

Appeal is allowed

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalexpedia Online Travel Services Income Tax Officer, India Private Limited, Ward-52(1), E-20, 1St & 2Nd Floor, Vs. Delhi. Hauz Khas Market, Hauz Khas, New Delhi-110016. Pan-Aabce7443H (Appellant) (Respondent) Assessee By Ms. Somyak Jain, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 29/07/2025 Date Of Pronouncement 31/07/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Final Assessment Order Dated 30. 07. 2024 Passed By The Assessment Unit, Income Tax Department (‘The Ao’ In Short) U/S 143(3) R.W.S. 144C(13)/144B Of The Income Tax Act, 1961 (‘The Act’ In Short) For Assessment Year 2020-21. 2. Ground Of Appeal No. 1 & 2 Are General In Nature Thus Not Adjudicated. 3. In This Case, The Assessee Has Raised Grounds Of Appeal Nos. 3 To 8 Challenging The Adjustment Of Rs.25,50,51,133/- On Account Of Technical Support Service. During The Course Of Hearing, The Ld. Ar Of The Assessee Submits That This Issue Has Been Rectified By The Revenue In Terms Of The Rectification Passed By Tpo Dated 16.07.2025. Copy Of Order Is Placed On Record, Therefore, Their Remain No Grievance To The Assessee And, Accordingly, The Ld. Ar Requested For Withdrawal Of This Ground Of Appeal. Expedia Online Travel Services India Pvt. Ltd. Vs. Ito 4. On The Other Hand, The Ld. Dr Has Not Objected To The Submissions Made. 5. Heard Both The Parties. Since, The Issue Raised By The Assessee In Appeal Has Been Settled By The Revenue In Terms Of The Order Passed U/S 154 Of The Act, Therefore, The Request Of The Assessee To Withdraw This Ground Of Appeal Is Allowed. Accordingly, The Ground Of Appeal No.1 Is Dismissed.

29/07/2025 Date of Pronouncement 31/07/2025 O R D E R PER MANISH AGARWAL, AM: This appeal is filed by the assessee against the final assessment order dated 30. 07. 2024 passed by the Assessment Unit, Income Tax Department (‘the AO’ in short) u/s 143(3) r.w.s. 144C(13)/144B

Fresenius Kabi Oncology Ltd, New Delhi vs. ITO, Ward-9(3), New Delhi

In the result appeal of the assessee is allowed

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalfresenius Kabi Oncology Ltd. Income Tax Officer, B-310, Som Dutt Chamber, Ward-9(3), Bhikaji Cama Place, Vs. New Delhi. New Delhi-110066. Pan-Aabcd7720L (Appellant) (Respondent)

passed the effect order on 26.11.2019 with a copy to the Jurisdictional assessing officer. The due date for passing of the final Assessment Order was 31.10.2019. Even if it is presumed that the order of ld. DRP was received by the AO in the month of October, 2019, the limitation ... completion of final assessment order u/s 144C(13) expired on 20.11.2019. However, the final Assessment Order was passed on 20.12.2019 which is in divergence to due date prescribed u/s144C (13) of the Act, the assessee submits that the final order passed by the Assessing Officer is barred by limitation

DCIT, Circle- 5(2), New Delhi vs. Carlsberg India Pvt. Ltd., New Delhi

In the result, the appeal filed by the assessee is allowed and appeal filed by the Revenue stands dismissed

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalcarlsberg India Private Limited, Dy. Cit, 4Th Floor, Rectangle No.1, Circle-5(2), Commercial Complex,D-4, Saket, Vs. New Delhi. New Delhi-110017. Pan-Aajcs8454J (Appellant) (Respondent) (Assessment Year 2010-11 Dy. Cit, Carlsberg India Private Circle-5(2), Limited, New Delhi. Vs. 4Th Floor, Rectangle No.1, Commercial Complex, D-4, Saket, New Delhi-110017. Pan-Aajcs8454J (Appellant) (Respondent) Assessee By Shri S.K. Aggarwal, Ca & Shri Paras Sharma, Ar & Ms. Ruchika Mittal, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 28/07/2025 Date Of Pronouncement 31/07/2025 Order

assessee. Thereafter, the Assessing Officer passed the draft assessment order making an addition of Rs.43.05 Cr. and, thereafter, the Assessing Officer passed the final assessment order and assessed the loss of the company to the tune of 64,23,45,205/-. 3. Aggrieved with the order

Carlsberg India Pvt. Ltd., New Delhi vs. DCIT, Circle- 5(2), New Delhi

In the result, the appeal filed by the assessee is allowed and appeal filed by the Revenue stands dismissed

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalcarlsberg India Private Limited, Dy. Cit, 4Th Floor, Rectangle No.1, Circle-5(2), Commercial Complex,D-4, Saket, Vs. New Delhi. New Delhi-110017. Pan-Aajcs8454J (Appellant) (Respondent) (Assessment Year 2010-11 Dy. Cit, Carlsberg India Private Circle-5(2), Limited, New Delhi. Vs. 4Th Floor, Rectangle No.1, Commercial Complex, D-4, Saket, New Delhi-110017. Pan-Aajcs8454J (Appellant) (Respondent) Assessee By Shri S.K. Aggarwal, Ca & Shri Paras Sharma, Ar & Ms. Ruchika Mittal, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 28/07/2025 Date Of Pronouncement 31/07/2025 Order

assessee. Thereafter, the Assessing Officer passed the draft assessment order making an addition of Rs.43.05 Cr. and, thereafter, the Assessing Officer passed the final assessment order and assessed the loss of the company to the tune of 64,23,45,205/-. 3. Aggrieved with the order

Irdeto Technology India Private Limited, Delhi vs. Assessing Unit, Income Tax Department, Delhi

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

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalirdeto Technology India Assessment Unit, Private Limited, Income Tax Department, 171, Somdutt Chambers-Ii, Vs. (Ld. Ao). Bhikaji Cama Place, New Delhi-110066, India Pan-Aabci3564M (Appellant) (Respondent) Assessee By Ms. Parul Girdhar, Ca Department By Shri S. K. Jadhav, Cit-Dr Date Of Hearing 22/07/2025 Date Of Pronouncement 30/07/2025 O R D E R Per Prakash Chand Yadav, Jm: The Present Appeal Of The Assessee Is Arising Out From The Order Of Ld. Assessing Officer Dated 25Th September, 2024 Having Din No. Itba/Ast/S/143(3)/2024-25/1069101879(1) & Relates To Assessment Year 2021-22. 2. The Assessee Has Raised Five Grounds Of Appeal, Out Of Which Ground No.3,4,5 Are Consequential & Hence, Does Not Require Adjudication.

while selecting comparable for bench marking the international transaction. Thereafter, the TPO passed the order giving effect and thus, the AO passed the final assessment order, impugned before us. 6. At the outset, the Ld. Counsel for the assessee appearing virtually contended that the assessee want an exclusion of only

Urb India Bearing Factory and Trade Pvt. Ltd., New Delhi vs. ITO Ward 27(1), New Delhi

In the result, the appeal of the assessee is allowed

Bench: Shri C. N. Prasad & Shri M. Balaganeshurb India Bearing Factory Vs. Ito & Trade Pvt. Ltd. Ward-27(1), C/O Co Working Space New Delhi Management Private Limited, 3Rd Floor, Kushal House, 39 Nehru Place, Delhi-110019 (Appellant) (Respondent) Pan: Aabcu3023H Assessee By : Ms. Rano Jain, Adv Ms. Mansi Jain, Ca Revenue By: Shri S. K. Jadav, Cit Dr Date Of Hearing 16/07/2025 Date Of Pronouncement 30/07/2025

with regard to ALP adjustment on sale of traded goods which culminated in framing of an addition of the same figure in the final assessment order. 9. Let us first get into the aspect of tinkering of the assessee‟s operating margin by the ld TPO. We find that

Ciena India Private Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle 4(2), Delhi

Accordingly, Ground No. 2 raised by the assessee is allowed

Bench: Shri Ramit Kochar & Ms. Madhumita Royciena India Private Vs. Dcit, Circle 4(2) Limited, Co Kochhar & C.R. Building, Co. Law Office, Suite No. Delhi – 110002 1120-1121, 11Th Floor, Tower A, Dlf Towers Jasola, New Friends Colony S.O Zakir Nagar So, South East, Delhi – 110025, "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaccc6131B Appellant .. Respondent

Assessment Year 2020-21. “1. That on the facts and circumstances of the case and in law, the final assessment order passed by the Ld. AO/ DRP is erroneous, contrary to the facts, based on surmises, conjectures and against the principles of natural justice and accordingly, the same is liable ... jurisdiction while issuing the draft assessment order dated 25 September 2023 passed under Section 144C(1) of the Act as well as final assessment order since the said power lies only with the National Faceless Assessment Centre as per the provisions of Section 144B of the Act and therefore

Uil Electronics India Private Limited, Gautam Budh Nagar vs. ACIT, DCIT, NFAC, Drp, Civic Center, New Delhi

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

Bench: SHRI PRAKASH CHAND YADAV (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

ACIT, DCIT, NFAC, DRP which the assessee filed its objection before the DRP, Ld. DRP affirmed the order of TPO. Thereafter, final assessment order, which is impugned before us, has been passed by the AO. Assessee has raised so many grounds of appeal, however the controversy involved in this appeal

Jaswin Kaur Sethi, Gurgaon vs. DCIT, International Taxation, Gurgaon

The appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishraassessment Year: 2020-21 Jaswin Kaur Sethi, Vs Dcit, 218, Regency Park, International Taxation, Dlf Phase Gurgaon. Gurgaon, Haryana – 122 009. Pan: Enmps7327R

Date of Hearing : 23.07.2025 Date of Pronouncement 30.07.2025 ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the assessee against the final assessment order dated 16.06.2023 of the Asstt. Commissioner of Income-tax (Appeals), International Taxation, Gurgaon (hereinafter referred as ‘the Ld. AO’) for Assessment Year 2020-21 passed ... residential land conversion rates of Delhi Development Authority (DDA) as notified by the Ministry of Urban Development, Government of India. Accordingly, the final assessment order 2 dated 16.06.2023 was passed giving effect to the directions of DRP and making an upward adjustment of Rs.92,47,70,400/- which has been