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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

Yrce Educate Pvt. Ltd, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle 2(1), Nagpur

ITA 245/NAG/2022[2018-2019]Status: DisposedITAT Nagpur09 Jun 2025AY 2018-2019

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

Yrce Educate Pvt. Ltd, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle 2(1), Nagpur

ITA 244/NAG/2022[2017-2018]Status: DisposedITAT Nagpur09 Jun 2025AY 2017-2018

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 143(3)Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

Umesh Sadashiv Thakre, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle 2(1), Nagpur

ITA 243/NAG/2022[2019-20]Status: DisposedITAT Nagpur09 Jun 2025AY 2019-20

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 143(3)Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

Umesh Sadashiv Thakre, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle 2(1), Nagpur

ITA 242/NAG/2022[2020-2021]Status: DisposedITAT Nagpur09 Jun 2025AY 2020-2021

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 143(3)Section 153A

suggestions given above. Therefore, only after making verifications, necessary enquiries and investigations in the light of the above suggestions made, the final assessment orders should be passed expeditiously as per the draft orders approved. The tax and interest calculations to 'be incorporated in the final orders should be checked ... Notice should be served on the assessee concerned expeditiously and the proof of service be placed in the assessment folders. Copies of the final assessment orders may be sent to this office for record." ii) Further, the above case law has distinguished Serajuddin and Co v/s ACIT, which

Umesh Sadashiv Thakre, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle 2(1), Nagpur

In the result, all the appeals filed by the assessee are allowed and all

ITA 241/NAG/2022[2018-2019]Status: DisposedITAT Nagpur09 Jun 2025AY 2018-2019

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 3

suggestions given above. Therefore, only _after_making verifications, necessary enquiries and investigations _in_the light of the above suggestions made, the_final assessment orders should be passed expeditiously as per the draft orders approved. The tax and interest calculations to ‘be incorporated in the final orders should be checked ... Notice should be served on the assessee concerned expeditiously and the proof of service be placed in the assessment folders. Copies of the final assessment orders may be sent to this office for record.” ii) Further, the above case law has distinguished Serajuddin and Co v/s ACIT, which

Umesh Sadashiv Thakre, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle 2(1), Nagpur

ITA 240/NAG/2022[F.Y.2017-18]Status: DisposedITAT Nagpur09 Jun 2025
Section 143(3)Section 153A

suggestions given above. Therefore, only after making verifications, necessary enquiries and investigations in the light of the above suggestions made, the final assessment orders should be passed expeditiously as per the draft orders approved. The tax and interest calculations to 'be incorporated in the final orders should be checked ... Notice should be served on the assessee concerned expeditiously and the proof of service be placed in the assessment folders. Copies of the final assessment orders may be sent to this office for record." ii) Further, the above case law has distinguished Serajuddin and Co v/s ACIT, which

Umesh Sadashiv Thakre, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle 2(1), Nagpur

In the result, all the appeals filed by the assessee are allowed and all

ITA 239/NAG/2022[2016-17]Status: DisposedITAT Nagpur09 Jun 2025AY 2016-17

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 153A

suggestions given above. Therefore, only after making verifications, necessary enquiries and investigations in the light of the above suggestions made, the final assessment orders should be passed expeditiously as per the draft orders approved. The tax and interest calculations to 'be incorporated in the final orders should be checked ... Notice should be served on the assessee concerned expeditiously and the proof of service be placed in the assessment folders. Copies of the final assessment orders may be sent to this office for record." ii) Further, the above case law has distinguished Serajuddin and Co v/s ACIT, which

Inlogic Technologies Private Limited, Chennai vs. DCIT Corp. Circle 1(1), Chennai

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

ITA 3323/CHNY/2024[2021-22]Status: DisposedITAT Chennai09 Jun 2025AY 2021-22

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकर अपीलसं./Ita No.: 3323/Chny/2024 िनधा"रण वष" / Assessment Year: 2021-22

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(3)Section 144BSection 153

Pronouncement : 09.06.2025 आदेश /O R D E R PER S. R. RAGHUNATHA, AM: This appeal filed by the assessee is directed against the final assessment order passed by the Assessment Unit, Income Tax Department, u/s. 143(3) r.w.s. 144C(13) r.w.s.144B of the Income Tax Act, 1961 (hereinafter ... Dispute Resolution Panel-2, Bengaluru dated 28.09.2024. 2. The assessee has raised the following grounds of appeal: GROUND 1 & 2- GENERAL 1. The final assessment order dated 23 October 2024 passed by the Learned AO under section 143(3) read with section l44C(13) read with section 144B

Assistant Commissioner of Income Tax Corporate Circle 1 1, Chennai vs. Hitachi Solutions India Private Limited, Kanchipuram

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

ITA 1715/CHNY/2024[2018-19]Status: DisposedITAT Chennai06 Jun 2025AY 2018-19

Bench: SHRI GEORGE GEORGE K, VICE PRESIDENT AND\nSHRI S.R. RAGHUNATHA, ACCOUNTANT MEMBER\nआयकर अपीलसं./IT(TP)A No.: 17/CHNY/2024\nनिर्धारण वर्ष / Assessment Year: 2018-19\nHitachi Solutions India Private\nLimited,\nBlock 5, 10th Floor, 1/124,\nDLF IT Park, Shivaji Gardens,\nMount Poonamallee Road,\nChennai - 600 089.\nThe Deputy Commissioner of\nIncome Tax,\nVs. Corporate Circle- 1(1),\nNo.121, M.G.Road,\nChennai - 600 034.\n[PAN:AAACZ-1544-R]\n(अपीलार्थी/Appellant)\n(प्रत्यर्थी/Respondent)\nआयकर

For Appellant: Shri Darpan Kirpalani, Advocate by VirtualFor Respondent: Shri A. Sasikumar, C.I.T
Section 143(3)Section 153Section 153(1)Section 153(4)

apparent from record. The TPO rejected the assessee's petitions and passed a rectification order on 18.03.2022. 8. The AO then passed the final assessment order dated 23.11.2021 (digitally signed on 25.11.2021) u/s.143(3) r.w.s.144C(3) r.w.s.144B of the Act along with the computation of income and notice of demand ... adjustments proposed by the AO as additions to the returned income of the assessee without making any further adjustments. Subsequent to the final assessment order, the assessee had filed a rectification petition u/s.154 on 03.03.2022, given short credit for TDS and excess interest u/s.234B of the Act, which is pending

Emerging Markets Index Non-Lendable Fund, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation )-2(2)(1), Mumbai

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

ITA 2073/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Anish Thacker &For Respondent: Shri Satya Pal Kumar, Sr.DR
Section 143(3)Section 144C(13)Section 144C(5)Section 270ASection 70Section 70(2)

02/06/2025 Date of Order - 06/06/2025 ORDER PER SANDEEP SINGH KARHAIL, J.M. The present appeals have been filed by separate assessee against the separate final assessment orders of even date 15/01/2025, passed under section 143(3) r.w. section 144C(13) of the Income Tax Act, 1961 (“the Act"), pursuant ... judicial finality on this issue. 10. In conformity with the directions issued by the learned DRP, the AO passed the impugned final assessment order under section 143(3) r.w. section 144C(13) of the Act computing the net short-term capital gains amounting to Rs.24,40,71,541 taxable

I Shares Esg Aware Msci Em Etf, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation ) -2(2)(2), Mumbai

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

ITA 2072/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Anish Thacker &For Respondent: Shri Satya Pal Kumar, Sr.DR
Section 143(3)Section 144C(13)Section 144C(5)Section 270ASection 70Section 70(2)

02/06/2025 Date of Order - 06/06/2025 ORDER PER SANDEEP SINGH KARHAIL, J.M. The present appeals have been filed by separate assessee against the separate final assessment orders of even date 15/01/2025, passed under section 143(3) r.w. section 144C(13) of the Income Tax Act, 1961 (“the Act"), pursuant ... judicial finality on this issue. 10. In conformity with the directions issued by the learned DRP, the AO passed the impugned final assessment order under section 143(3) r.w. section 144C(13) of the Act computing the net short-term capital gains amounting to Rs.24,40,71,541 taxable

Emerging Markets Equity Index Master Fund, Mumbai vs. Deputy CIT (Int. Tax)-2(2)(1), Mumbai

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

ITA 2040/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Anish Thacker &For Respondent: Shri Satya Pal Kumar, Sr.DR
Section 143(3)Section 144C(13)Section 144C(5)Section 270ASection 70Section 70(2)

02/06/2025 Date of Order - 06/06/2025 ORDER PER SANDEEP SINGH KARHAIL, J.M. The present appeals have been filed by separate assessee against the separate final assessment orders of even date 15/01/2025, passed under section 143(3) r.w. section 144C(13) of the Income Tax Act, 1961 (“the Act"), pursuant ... judicial finality on this issue. 10. In conformity with the directions issued by the learned DRP, the AO passed the impugned final assessment order under section 143(3) r.w. section 144C(13) of the Act computing the net short-term capital gains amounting to Rs.24,40,71,541 taxable

Schindler India Private Limited, Mumbai vs. Income-Tax Officer, Mumbai

In the result, the appeal filed by the assessee is disposed off in light of aforesaid directions

ITA 4819/MUM/2024[AY 2020-21]Status: DisposedITAT Mumbai06 Jun 2025

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2020-21 Schindler India Private Limited, The Asst. Commissioner Of Schindler House, Income Tax, Main Street, Vs. Circle-15(3)(2) Hiranandani Gardens, Aayakar Bhavan, Powai, Maharshi Karve Road, Mumbai -400076 New Marine Lines, [Pan: Aaecs1548J] Churchgate, Mumbai-400020 (Appellant) (Respondent)

For Appellant: Ms. Chandani Shah a/wFor Respondent: Shri Ajay Chandra, CIT-DR
Section 143(3)Section 144CSection 144C(8)Section 270ASection 274Section 37(1)Section 92C

total income of INR 1,35,83,96,724/- 1.2. On the facts and circumstances of the case and in law, the final assessment order dated 23 July 2024 is issued beyond the time limit as prescribed w/s 153 of the Act. Consequently, the final assessment order is time barred ... under section 37(1). Accordingly, the directions of the Hon'ble DRP are bad in law and ought to be quashed. Consequently, the final assessment order dated 23 July 2024, is bad in law and ought to be quashed. 1.4. Without prejudice to the above ground, on the facts

Kuldeep Marwah, Kaithal vs. DCIT-ACIT-Int-Tax, Gurgaon

The appeal of the assessee is allowed

ITA 590/DEL/2024[2018-19]Status: DisposedITAT Delhi06 Jun 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2018-19 Kuldeep Marwah, Vs Dcit, House No.221/10, International Taxation, Marwah Cottage, Gurgaon. Karnal Road, Kaithal, Haryana – 136 027. Pan: Aiapm5225F (Appellant) (Respondent) Assessee By : Shri Shaatanu Jain, Advocate & Shri Gurjeet Singh, Ca Revenue By : Ms Ekta Jain, Cit-Dr Date Of Hearing : 05.05.2025 Date Of Pronouncement : 06.06.2025 Order Per Anubhav Sharma, Jm:

For Appellant: Shri Shaatanu Jain, Advocate &For Respondent: Ms Ekta Jain, CIT-DR
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 151Section 195Section 69A

Date of Hearing : 05.05.2025 Date of Pronouncement : 06.06.2025 ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the Assessee against the final assessment order dated 16.01.2024 passed by the Asstt. Commissioner of Income-tax, International Taxation, Gurgaon (hereinafter referred to as the Ld. AO) u/s 147 r.w.s. 144C ... declaration form and certificate of foreign inward remittances which has been accepted by the DRP and, consequently, deleted by the AO in the final assessment order. 8. Thus, where there is no other alleged source of income accruing or arising in India, then, for failure to file any bank statement

Rajeev Malik, New Delhi vs. ACIT Central Intl. Taxation 2(2)(1), New Delhi

The appeal is allowed

ITA 1896/DEL/2024[2016-17]Status: DisposedITAT Delhi06 Jun 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2016-17 Rajeev Malik, Vs Acit, Central, 26/28, East Patel Nagar, International Taxation 2(2)(1), New Delhi – 110 008. New Delhi. Pan: Agbpm6372N (Appellant) (Respondent) Assessee By : Shri Gautam Jain, Advocate & Shri Ankit Kumar, Advocate Revenue By : Ms Ekta Jain, Cit-Dr Date Of Hearing : 05.05.2025 Date Of Pronouncement : 06.06.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Final Assessment Order Dated 28.03.2024 Passed By The Asstt. Commissioner Of Income-Tax, International Taxation-2(2)(1), New Delhi (Hereinafter Referred To As The Ld. Ao) U/S 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For Ay 2016-17. 2. On Hearing Both The Sides, We Find That Amongst Other Grounds On Merits, The Assessee Has Raised Ground No.2 As Follows:-

For Appellant: Shri Gautam Jain, Advocate &For Respondent: Ms Ekta Jain, CIT-DR
Section 1Section 147Section 148Section 148ASection 151Section 3

Date of Hearing : 05.05.2025 Date of Pronouncement : 06.06.2025 ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the Assessee against the final assessment order dated 28.03.2024 passed by the Asstt. Commissioner of Income-tax, International Taxation-2(2)(1), New Delhi (hereinafter referred

Gemini Property Developments India LLP, Mumbai vs. Income-Tax Officer-Ward 28(1)(1), Mumbai

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

ITA 1435/MUM/2025[2017-18]Status: DisposedITAT Mumbai05 Jun 2025AY 2017-18

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 133(3)Section 263

legal principles of consistency, burden of proof, and adherence to statutory filings” 5. On receipt of the DRP direction, the Ld.AO passed the final assessment order on 30/01/2025 making addition in the hands of the assessee as proposed by the transfer pricing officer. Aggrieved by the order of the Ld.AO

Sh. Rajinder Singh Bedi, Chandigarh vs. DCIT (Intl. Taxation), Chandigarh

In the result, appeal of the assessee is allowed

ITA 538/CHANDI/2022[2018-19]Status: DisposedITAT Chandigarh04 Jun 2025AY 2018-19

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 538/Chd/2022 "नधा"रण वष" / Assessment Year: 2018-19 Shri Rajinder Singh Bedi, The Dcit, (Int.Taxation ), 1368, Sector 40-B, Vs Chandigarh. Chandigarh. "थायी लेखा सं./Pan No: Afwpb3355A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Sudhir Sehgal, Advocate Revenue By : Smt. Kusum Bansal, Cit, Dr Date Of Hearing : 09.04.2025 Date Of Pronouncement : 04.06.2025 Hybrid Hearing O R D E R

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 143(2)Section 143(3)Section 144Section 144CSection 144C(13)Section 144C(2)(b)Section 144C(5)

Registered Valuer's report DVO 528.125 7073 2981.44 339 Draft Assessment Order 528.125 3621 (based on 3302.51 350 Circle rate Final Assessment Order 528.125 3621 . 2000 350 4. A perusal of the above detail would indicate that total area of the land is 528.125 sq.yd. There was no dispute about

Pos-Hyundai Steel Manufacturing India Private Limited, Kanchipuram vs. Deputy Commissioner of Income Taxof Income Tax Circle 1 Ltu, Chennai

In the result the appeal of the Assessee is allowed

ITA 2485/CHNY/2024[2020-21]Status: DisposedITAT Chennai04 Jun 2025AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:2485/Chny/2024 िनधा"रण वष" / Assessment Year: 2020-21 Pos – Hyundai Steel Manufacturing Deputy Commissioner Of Income India Private Limited, Vs. Tax, F-70, Sipcot Industrial Park, Circle -1, Ltu, Irungattukottai S.O., Chennai. Kanchipuram – 602 117. [Pan:Aaacp-6484-G] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri. B. Srinath, C.AFor Respondent: Shri. A. Sasikumar, C.I.T
Section 143(3)Section 144C(5)

Pronouncement : 04.06.2025 आदेश /O R D E R PER S. R. RAGHUNATHA, ACCOUNTANT MEMBER: This appeal filed by the assessee is directed against final assessment order passed by the Assessing Officer u/s. 143(3) r.w.s. 144C(13) of the Income-tax Act, 1961 for AY 2020-21 dated 26.07.2024, pursuant ... principle upheld TP adjustment except for directing the TPO to adopt the correct margins of the comparable. Thereafter, the AO passed final assessment order u/s.143(3) r.w.s. 144C(13) of the Act for AY 2020-21 and determined total income of Rs.9,93,58,590/-. Aggrieved by the aforementioned order

Anand Swarup Mehta, Mumbai vs. Income Tax Officer(International Tax)-3(2)(1), Mumbai

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

ITA 851/MUM/2025[2022-23]Status: DisposedITAT Mumbai04 Jun 2025AY 2022-23

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 111ASection 142(1)Section 143(2)Section 144C(5)

Directions of the DRP: In view of the above discussion, the objections of the Applicant fail. On the basis of these directions, the final assessment order was passed which has been challenged before us in this appeal and assessee has raised the following grounds:- 1. General Ground 1.1 That

Lions Gate India LLP, Mumbai vs. Assessment Unit, National Faceless Assessment Centre, Income Tax Department, Delhi, Mumbai

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

ITA 4970/MUM/2024[AY 2020-21]Status: DisposedITAT Mumbai04 Jun 2025

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Ms. Bhumika Majethiya, AR (virtually)For Respondent: Shri Bhagirath Ramawat, Sr. DR
Section 144C(5)Section 153Section 92CSection 92C(3)

erred in not appreciating that the time limit under Section 153 of the Act is the outer limit for passing of the final assessment order and hence, the final assessment order dated 29 July 2024 is time barred and liable to be quashed; Reference to the ТРО 5. erred ... resulting to INR 4,47,64,426) as against the adjustment of INR 4,47,78,175 as per the Final Assessment order; Transfer Pricing adjustment on Technical Fees for use of OTT platform services Rejection of economic analysis undertaken by the Appellant 12. erred in rejecting the economic analysis