← All Phrases

“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

ITO, Kolkata vs. Sujata Kayan, Kolkata

In the result, all the appeals filed by the revenue are dismissed

ITA 2382/KOL/2024[2016-17]Status: DisposedITAT Kolkata24 Jul 2025AY 2016-17

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 148Section 148ASection 149

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

ITO, Kolkata vs. Sujata Kayan, Kolkata

In the result, all the appeals filed by the revenue are dismissed

ITA 2381/KOL/2024[2015-16]Status: DisposedITAT Kolkata24 Jul 2025AY 2015-16

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 148Section 148ASection 149

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

Ajit Kumar, Bangalore vs. ACIT, International Taxation, Circle-1(2), Bangalore

In the result, appeal filed by the assessee is allowed

ITA 449/BANG/2025[2015-2016]Status: DisposedITAT Bangalore24 Jul 2025AY 2015-2016

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kit(It)A No.449/Bang/2025 Assessment Year : 2015-16

For Appellant: Shri. C. Ramesh, ARFor Respondent: Dr. Divya K. J, CIT(DR)(ITAT), Bangalore
Section 139Section 139(1)Section 143(2)Section 144C(1)Section 144C(5)Section 148Section 148ASection 239(1)

hearing : 08.07.2025 Date of Pronouncement : 24.07.2025 ORDER Per Laxmi Prasad Sahu, Accountant Member : This appeal filed by the assessee is against the final assessment order passed by the CIT(A), under ection 147 r.w.s. 144C(13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’), for the Assessment Year ... Order under section 144C(5) of the Act on 08.11.2024, dismissing the objections raised before them. In pursuant to the direction of DRP, final Assessment Order was passed on 30.12.2024. 5. Aggrieved from the above final Assessment Order, assessee filed appeal before us. The learned Counsel reiterated the submissions made

Dell International Services India Private Limited, Bangalore, Karnataka vs. Deputy Commissioner of Income-Tax, Circle - 2(1)(1), Bangalore, Karnataka

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

ITA 1488/BANG/2024[2014-15]Status: DisposedITAT Bangalore24 Jul 2025AY 2014-15

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kit(Tp)A No.1488/Bang/2024 Assessment Year : 2014-15

For Appellant: Ms. Tanmaye Rajkumar, ARFor Respondent: Dr. Divya K. J, CIT(DR)(ITAT), Bangalore
Section 144C(13)Section 92C

passed an order dated 27.10.2017 determining a TP adjustment of Rs. 2,39,71,904/-. Subsequently, the Assessing Officer passed a final assessment order dated 29.01.2018 incorporating the said TP adjustment. 4. Aggrieved by the final assessment order, the Appellant filed an appeal before the Commissioner of Income Tax (Appeals

O.C Tanner India Private Limited, Mumbai vs. DCIT, Circle -2(3)(1), Mumbai

In the result the appeal is, accordingly, he appeal is, accordingly, allowed for statistical allowed for statistical purposes

ITA 5785/MUM/2024[2021-22]Status: DisposedITAT Mumbai24 Jul 2025AY 2021-22

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2021-22 O.C. Tanner India Pvt. Ltd., Dy. Cit, Circle-2(3)(1), No. 2, Lave 7 Tower 2, Phase Ii, 552, 5Th Floor, Aayakar Bhavan, Raiaskaran Techpark Andheri Vs. Maharishi Karve Road, Kurla Road, Andheri East, Mumbai-400020. Sakinaka S.O. Mumbai, Mumbai-400072. Pan No. Aabco 1031 F Appellant Respondent

For Appellant: Mr. Vijay Mehta, CA
Section 144C(13)Section 144C(5)

Date of Hearing : 10/07/2025 : 24/07/2025 Date of pronouncement ORDER PER OM PRAKASH KANT, AM This appeal by the assessee is directed against final assessment order dated 10.09.2022, passed by the Assessment Unit, Income-tax Department [in short ‘the Ld. Assessing Officer’] for assessment year 2021-22, pursuant to the direction ... under section 144C(5) of the Act of the Act. Pursuant to those directions, the AO passed the ons, the AO passed the final assessment order final assessment order under O.C. Tanner India Pvt. Ltd O.C. Tanner India Pvt. Ltd section 144C(13), upholding the transfer pricing adjustments in section

DCIT Central Circle-1(2), Ahmedabad vs. Faridabanu Faridmiya Shaikh Wife & Legal Heir of Late Faridmiya Hussenmiya Shaikh, Ahmedabad

In the result, the appeal filed by the Revenue in ITA No

ITA 873/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad23 Jul 2025AY 2022-23

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 131Section 132Section 132(4)Section 139(1)Section 142(1)Section 143Section 148Section 69A

Court judgment in the case of Riknu R. Rai vs. ITO reported in [2023] 454 ITR 33 (Bom) for the proposition that the final assessment order is liable to be quashed, as no draft assessment order was issued to the assessee. 5.2. In our considered view, the above provisions

Deputy Commissioner of Income -Tax, Central Circle-1(2), Ahmedabad vs. Faridabanu Faridmiya Shaikh Wife & Legal Heir of Late Faridmiya Hussenmiya Shaikh, Ahmedabad

In the result, the appeal filed by the Revenue in ITA No

ITA 872/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad23 Jul 2025AY 2021-22

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 131Section 132Section 132(4)Section 139(1)Section 142(1)Section 143Section 148Section 69A

Court judgment in the case of Riknu R. Rai vs. ITO reported in [2023] 454 ITR 33 (Bom) for the proposition that the final assessment order is liable to be quashed, as no draft assessment order was issued to the assessee. 5.2. In our considered view, the above provisions

Deputy Commissioner of Income -Tax Central Circle-1(2), Ahmedabad vs. Faridabanu Faridmiya Shaikh Wife & Legal Heir of Late Faridmiya Hussenmiya Shaikh, Ahmedabad

In the result, the appeal filed by the Revenue in ITA No

ITA 871/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad23 Jul 2025AY 2020-21

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 131Section 132Section 132(4)Section 139(1)Section 142(1)Section 143Section 148Section 69A

Court judgment in the case of Riknu R. Rai vs. ITO reported in [2023] 454 ITR 33 (Bom) for the proposition that the final assessment order is liable to be quashed, as no draft assessment order was issued to the assessee. 5.2. In our considered view, the above provisions

Faridabanu Faridmiya Sheikh Legal Heir of Late Faridmiya Hussenmiya Sheikh, Ahmedabad vs. ACIT Central Circle-1(2), Ahmedabad

In the result, the appeal filed by the Revenue in ITA No

ITA 681/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad23 Jul 2025AY 2022-23

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 131Section 132Section 132(4)Section 139(1)Section 142(1)Section 143Section 148Section 69A

Court judgment in the case of Riknu R. Rai vs. ITO reported in [2023] 454 ITR 33 (Bom) for the proposition that the final assessment order is liable to be quashed, as no draft assessment order was issued to the assessee. 5.2. In our considered view, the above provisions

Faridabanu Faridmiya Sheik Legal Heir of Late Faridmiya Hussenmiya Sheikh, Ahmedabad vs. ACIT Central Circle -1(2), Ahmedabad

In the result, the appeal filed by the Revenue in ITA No

ITA 680/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad23 Jul 2025AY 2021-22

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 131Section 132Section 132(4)Section 139(1)Section 142(1)Section 143Section 148Section 69A

Court judgment in the case of Riknu R. Rai vs. ITO reported in [2023] 454 ITR 33 (Bom) for the proposition that the final assessment order is liable to be quashed, as no draft assessment order was issued to the assessee. 5.2. In our considered view, the above provisions

Faridabanu Faridmiya Sheikh Legal Heir of Late Faridmiya Hussenmiya Sheikh, Ahmedabad vs. ACIT Central Circle-1(2), Ahmedabad

In the result, the appeal filed by the Revenue in ITA No

ITA 679/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad23 Jul 2025AY 2020-21

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 131Section 132Section 132(4)Section 139(1)Section 142(1)Section 143Section 148Section 69A

Court judgment in the case of Riknu R. Rai vs. ITO reported in [2023] 454 ITR 33 (Bom) for the proposition that the final assessment order is liable to be quashed, as no draft assessment order was issued to the assessee. 5.2. In our considered view, the above provisions

Oman Telecommunications Company Saog, Oman vs. Deputy Commissioner of Income Tax/ Circle International Tax 2(2)(2), Delhi

In the result, appeal is partly allowed

ITA 1023/DEL/2025[2018-19]Status: DisposedITAT Delhi23 Jul 2025AY 2018-19

Bench: Shri Prakash Chand Yadav & Shri Naveen Chandraoman Telecommunications Deputy Commissioner Company Saog Of Income Tax/Circle Vp Finance Office, Po Box 789, Vs. International Tax Postal Code 11, Ruwi Muscat, 2(2)(2), Delhi. Sultanate Of Oman Outside India Pan-Aabco4203F (Appellant) (Respondent) Assessee By Ms. Ananya Kapoor, Adv. Department By Shri Nikhil Kumar Govila, Cit-Dr Date Of Hearing 16/07/2025 Date Of Pronouncement 23/07/2025 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 December, 2024 Having Din & Order No. Itba/Ast/S/147/2024-25/1071556765(1) Dated 25/12/2024 & Relates To Assessment Year 2018-19. 2. Brief Facts Of The Case As Coming Out From The Orders Of The Authorities Below Are That The Assesse Is Foreign Company & Had Not Filed Return Of Income For The Impugned Year. Thereafter, The Case Of The Assessee Was Reopened U/S 148 Of The Income Tax Act, 1961 On The Ground That Assessee Has Received Certain Payments From Two Indian Entities Namely M/S Bharti Airtel Limited & M/S Vodafone Mobile Services Ltd & Has Not Shown Any Income In India. The Assessing Officer Was Of The View That The Service Provided By The Assessee To The Indian Entities Were In The Nature Of The Fts And, Hence, Taxable In India. The Oman Telecommunications Company Saog Vs. Dcit Assessing Officer Relied Upon The Provisions Of Section 9(I)(Vii) Of The Act Held That The Service Rendered By The Assessee Are In The Nature Of Technical Services And, Hence, The Same Are Taxable In India. Accordingly, The Assessing Officer Made Addition Of Rs. 11,81,52,790/. Drp Also Affirmed The View Of The Ao Vide Order Dated 4Th November, 2024. Thereafter, Ld. Ao Framed The Final Assessment Order.

Section 148Section 56Section 9Section 9(1)(vi)Section 9(1)(vii)

also affirmed the view of the AO vide order dated 4th November, 2024. Thereafter, Ld. AO framed the final assessment order. 3. Aggrieved with the order of the AO, the assessee has come up in appeal. 4. At the outset, the Ld. Counsel for the assessee pointed that the similar

Vedanta Limited, New Delhi vs. ACIT, Circle-25(1), New Delhi

In the result, appeal of the assessee is dismissed in the terms aforesaid

ITA 759/DEL/2023[2013-14]Status: DisposedITAT Delhi23 Jul 2025AY 2013-14

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

For Appellant: Shri Harmeet Singh, ARFor Respondent: Shri Dharam Veer Singh, CIT DR
Section 254

RIFAUR RAHMAN, ACCOUNTANT MEMBER : 1. This appeal has been filed by the assessee against the final assessment order dated 27.01.2023 passed u/s 254/143(3)/144c r.w.s.144C (13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’) subsequent to the directions of the Ld. Dispute Resolution Panel (DRP)/TPO

Albert Joseph Rozario, Mumbai vs. ITO, Int. Tax, Circle 4(1)(1), Mumbai

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

ITA 1168/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Jul 2025AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Albert Joseph Rozario, Ito, (Int. Tax), Circle-4(1)(1), B-311, 5Th Wing, Room No. 629, 6Th Floor, Inlaks Park, Vs. Kautilya Bhavan, Yari Road, Versova, C-41 To C-43, G Block, Andheri West, Bandra Kurla Complex, Mumbai-400058 Bandra East, Pan : Afvpr6139P Mumbai-400051 (Appellant) (Respondent) For Assessee : Shri Dharan Gandhi For Revenue : Shri Sridhar G. Menon, Sr.Dr Date Of Hearing : 01-05-2025 Date Of Pronouncement : 22-07-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Final Assessment Order Passed By The Assessing Officer U/S 147 R/W 144C(13) Of The Act Dt. 30-12-2024, Consequent To The Directions Given By The Ld. Drp-1, Mumbai-3, U/S 144C(5) Of The Act, Dated 30-11-2024 Pertaining To Assessment Year (Ay.) 2018-19. 2. Briefly The Facts Of The Case Are That Basis Information Available Through The Insight Portal That The Assessee Had Purchased Immoveable Properties Amounting To Rs. 8,31,45,549/- & Has Received Interest

For Appellant: Shri Dharan GandhiFor Respondent: Shri Sridhar G. Menon, Sr.DR
Section 144C(1)Section 144C(5)Section 147Section 148Section 148ASection 56(2)(x)Section 69

VIKRAM SINGH YADAV, A.M : This is an appeal filed by the assessee against the final assessment order passed by the Assessing Officer u/s 147 r/w 144C(13) of the Act dt. 30-12-2024, consequent to the directions given by the Ld. DRP-1, Mumbai-3, u/s 144C ... made by the AO was held to be good in law. 6. Following the aforesaid directions of the DRP, the AO passed the final assessment order u/s. 147 r.w.s. 144C(13) of the Act, vide order dt. 30-12- 2024; wherein the unexplained investment

Nilesh Purshottam Ghodasara, Mumbai vs. DCIT Circle Int Tax 1(3)(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 297/DEL/2023[2015-16]Status: DisposedITAT Delhi22 Jul 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2015-16]

Section 142(1)Section 144Section 144CSection 144C(1)Section 144C(15)Section 147Section 148Section 69Section 92C

objections made at ground no. 1 to 3, in this regard are hereby, disposed off accordingly. 6. The Assessing Officer passed the final assessment order on 21.01.2023. In the final order, the Assessing Officer stated that as per the directions of the ld. DRP, the case was re-examined again

Vinita Bajoria, Jaipur vs. Income-Tax Officer, Jaipur

In the result, the appeal of the assessee is allowed

ITA 370/JPR/2025[201617]Status: DisposedITAT Jaipur21 Jul 2025

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं./ITA No. 370/JP/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Vinita Bajoria 1, Ganesh Colony Moti Doongri Road, Jaipur बनाम Income Tax Officer, Ward 5(2), Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AEBPB4873M अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Sh. Manoj Choudhary, CA राजस्व की ओर से / Revenue by : Sh. Gorav Avasthi, JCIT सुनवाई की तारीख / Date of Hear

For Appellant: Sh. Manoj Choudhary, CAFor Respondent: Sh. Gorav Avasthi, JCIT
Section 147Section 148Section 148A

reasons of reopening it was mentioned that the assessee has not filed the return of income whereas in the final assessment order it was mentioned that the assessee had filed the return of income for the relevant assessement year. This is a distinguishing fact. -The Ld. A/R has not appreciated

Pandurang Kashinath Bhilare, Pune vs. ITO, (It) Ward 1, Pune

In the result the appeal of the Assessee is allowed

ITA 198/PUN/2025[2018-19]Status: DisposedITAT Pune21 Jul 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.198/Pun/2025 िनधा"रण वष" / Assessment Year: 2018-19 Pandurang Kashinath Bhilare, V The Income Tax Rh 05, Insignia, Lane 2, S Department, Ito,(It) Pashan Sus Road, N.I.A.S.O., Ward-1, Pune. Murkutenagar(N.V.), Pune – 411045. Maharashtra. Pan: Ajxpb9871A Appellant/ Assessee Respondent / Revenue Assessee By Assessee In Person Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 05/06/2025 Date Of Pronouncement 21/07/2025

Section 147Section 43CSection 56(2)(x)

Assessee had appeared and had filed copy of the agreement to sale. The case was heard on 05.06.2025. 3. As per the Final Assessment Order, Assessee is an Individual and a Non-Resident Indian in the assessment year concerned. As per information flagged on Insight Portal and available

Balasubramanian Saravanan, Chennai vs. ITO, Ncw-17(7), Chennai

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

ITA 1498/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Jul 2025AY 2017-18

Bench: Shri George George Kand Shri S.R. Raghunatha

For Appellant: Shri Abhishek Murali, CAFor Respondent: Shri AR. V. Sreenivasan, CIT
Section 119(2)(b)Section 139(1)Section 143(1)Section 250Section 90

present case. In the present case, the returns were filed without foreign tax credit, however the same was filed before passing of the final assessment order. The filing of foreign tax credit in terms of the rule 128 is only directory in nature. The rule is only for the implementation ... petitioner on February 2, 2021. The respondent is directed to give due credit to the Kenya income of the petitioner and pass the final assessment order. Further, it is made clear that the impugned order is set aside only to the extent of disallowing of foreign tax credit claim made

Green Maiden A 2013, Mumbai vs. The Assistant Commissioner of Income Tax International Tax Circle 2(3)(2), Mumbai

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

ITA 1986/MUM/2025[2019-20]Status: DisposedITAT Mumbai21 Jul 2025AY 2019-20

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Ms. Hirali Desai/ Shri Hardik Nirmal/ MsFor Respondent: Shri Krishna Kumar, Sr.DR
Section 144C(13)Section 144C(5)Section 147Section 153Section 61Section 63

Hearing – 17/07/2025 Date of Order - 21/07/2025 ORDER PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeal against the impugned final assessment order dated 24/01/2025, passed under section 147 read with section 144C(13) of the Income Tax Act, 1960 (“the Act”) by the Assessing Officer ("AO”), pursuant ... others: 1. Ground No. 1 - Assessment order is barred by limitation On the facts and in the circumstances of the case, the final assessment order dated 24 January 2025 passed by the Assessing officer under section 147 r.w.s.144C(13) of the Act having been passed beyond the limitation provided

Daido India Pvt. Ltd., Gurgaon vs. DCIT, Circle- 1(1), Gurgaon

ITA 5761/DEL/2018[2014-15]Status: DisposedITAT Delhi21 Jul 2025AY 2014-15

Bench: Shri Ramit Kochar & Sh. Yogesh Kumar U.S.

Section 142(1)Section 143(2)Section 143(3)Section 271(1)(c)Section 92C

Hearing 22/04/2025 Date of Pronouncement 21/07/2025 ORDER PER YOGESH KUMAR, U.S. JM: The present appeal is filed by the Assessee against the final assessment order dated 09/07/2018 passed u/s 143(3)/ 144C of the Income Tax Act, 1961 ('Act' for short) pertaining to the Assessment Year ... international transaction G 43,48,17,719 Proportionate cost H=G/C 82.48% Adjustment I=F*H 4,39,30,329/- 6. A final assessment order came to be passed u/s 143(3)/144C of the Act by making the adjustment of Rs.4,39,30,329/- to international transactions pertaining