“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

Owens Corning (Singapore) Pte Ltd, Mumbai vs. Deputy Commissioner of Income Tax (International Tax ) Circle -3(2)(2), Mumbai

In the result, the appeal by the assessee is allowed

ITA 1238/MUM/2025[2022-23]Status: DisposedITAT Mumbai14 May 2025AY 2022-23

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailowens Corning (Singapore) Pte Ltd., C/O Owens Corning (India) Pvt. Ltd., 7Th Floor, Alpha Building, Hiranandani Gardens, Powai ............... Appellant Maharashtra - 400076 Pan : Aabco5666L V/S Dcit (It) – 3(2)(2) 6Th Floor, Kautilya Bhawan, ……………… Respondent Bandra Kurla Complex, Mumbai - 400051

For Appellant: Shri Sandeep BhallaFor Respondent: Shri Soumendu Kumar Dash, Sr.DR

Section 115ASection 142(1)Section 143(2)Section 143(3)Section 144C(13)Section 234BSection 9Section 9(1)(vii)Section 90(2)

Order - 14/05/2025 O R D E R PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeal against the impugned final assessment order dated 26/12/2024, passed under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the directions issued ... protect the interest of the Revenue. 7. In conformity with the directions issued by the learned DRP, the AO vide impugned final assessment order dated 26/12/2024, assessed the fabrication charges received by the assessee as FTS under section 9(1)(vii) read with 6 Article 12(4) of the India

Garimella Venkata Appala Sarma, Visakhpatnam vs. Income-Tax Officer, Ward (International Taxation), Visakhapatnam

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

ITA 149/VIZ/2025[20189-19]Status: DisposedITAT Visakhapatnam13 May 2025

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.149/Viz/2025 (निर्धारणवर्ा/ Assessment Year: 2018-19) Garimella Venkata Appala Sarma V. Income Tax Officer – Ward – (International Taxation) Flat No. L-523, Mk Gold Coast Income Tax Office Yendada, Visakhapatnam – 530045 Infinity Towers, Sankaramatam Road Andhra Pradesh Visakhapatnam – 530016 [Pan: Anppg5223K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 144Section 144CSection 148Section 148ASection 69A

आदेश /O R D E R PER SHRI S BALAKRISHNAN, ACCOUNTANT MEMBER: 1. This appeal is filed by the assessee against the final assessment order passed under section 144 r.w.s. 144C(13) of the Income Tax Act, 1961 (in short ‘Act’) dated 21.01.2025 vide DIN & Order No. ITBA/AST/S/144/2024- 25/1072391196 ... dismissing the objections raised by the assessee. Based on the directions of the DRP, Ld. AO passed the final assessment order giving effect to the direction of the DRP on 21.01.2025. 4. On being aggrieved by the final assessment order, assessee filed an appeal before us by raising following grounds

Vijaya Lakshmi Ravula, Guntur vs. Income Tax Officer, Ward-2(1), Guntur

In the result, all the 4 appeals of the assessee are allowed

ITA 218/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam13 May 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri S. Balakrishnanappeal No. Assessee Respondent A.Y 209/Viz/2024 Konda Srinivasa Income Tax Officer 2016-17 Reddy, Guntur, Ward 2(1) Pan:Aafhk9821E Guntur 216/Viz/2024 Veerareddy Gogula - Do - -Do- Guntur Pan:Byapg6481J - Do - 217/Viz/2024 Swarajyam -Do- Dontireddy Guntur Pan:Cmmpd3393K - Do - 218/Viz/2024 Vijaya Lakshmi -Do- Ravula, Guntur Pan:Baopr0163G

For Appellant: Shri C. Subrahmanyam, CAFor Respondent: : Shri Satyasai Rath, DR

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 2(47)Section 263Section 53A

development agreement entered into between the co-owner and the developer. He has referred to the draft assessment order as well as the final assessment order and submitted that the Assessing Officer has discussed this issue on facts as well as on law and finally taken a view that there ... Gain of Rs.10.65 crores whereas after considering the reply and various judgments relied upon b y the assessee, the Assessing Officer in the final assessment order have not made the said addition. This itself shows that the Assessing Officer has taken a decision after considering the relevant fact as well

Swarajyam Dontireddy, Guntur vs. Income Tax Officer, Ward-2(1), Guntur

In the result, all the 4 appeals of the assessee are allowed

ITA 217/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam13 May 2025AY 2016-17

For Appellant: Shri C. Subrahmanyam, CAFor Respondent: : Shri Satyasai Rath, DR

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 2(47)Section 263Section 53A

Veerareddy Gogula, Guntur vs. Income Tax Officer, Ward-2(1), Guntur

In the result, all the 4 appeals of the assessee are allowed

ITA 216/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam13 May 2025AY 2016-17

For Appellant: Shri C. Subrahmanyam, CAFor Respondent: : Shri Satyasai Rath, DR

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 2(47)Section 263Section 53A

Konda Srinivasa Reddy, Guntur vs. Income Tax Officer, Ward-2(1), Guntur

In the result, all the 4 appeals of the assessee are allowed

ITA 209/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam13 May 2025AY 2016-17

For Appellant: Shri C. Subrahmanyam, CAFor Respondent: : Shri Satyasai Rath, DR

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 2(47)Section 263Section 53A

Chand Beebi, Palakkad vs. DCIT, Circle Int.Tax, Kochi

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

ITA 1057/COCH/2024[2018-19]Status: DisposedITAT Cochin13 May 2025AY 2018-19

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am

For Appellant: Shri Pathmanathn K.V., AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 143(3)Section 144CSection 148

Pronouncement: 13.05.2025 O R D E R Per: Inturi Rama Rao, AM This appeal filed by the assessee is directed against the final assessment order passed u/s. 143(3) r.w.s. 144C(1) of Income Tax Act, 1961 (hereinafter "the Act") dated 30.01.2024 for Assessment Year (AY) 2018-19. 2. Brief ... objections by holding that the valuation report filed by the assessee is not from the District Valuation Officer (DVO). The AO passed the final assessment order on 06.11.2024 by making addition of Rs. 11,84,968/- under the head ‘capital gains’. 3. Being aggrieved, the appellant is in appeal before

Babudeen and Party, Jaipur vs. I.T.O. Ward 6(1), Jaipur

In the result, the appeal of the assessee is allowed

ITA 129/JPR/2025[A.Y. 2000-01]Status: DisposedITAT Jaipur13 May 2025

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. G. M. Mehta, C.AFor Respondent: Mrs. Anita Rinesh, JCIT

Section 144Section 154Section 220(2)Section 254

interest being compensatory in nature, the revenue is entitled to charge the same from the date of original order which merged with the final assessment order. f) In this case, set aside assessment order is merged with original order and the assessee becomes liable to pay interest

Sh. Bagga Singh, Jalandhar vs. DCIT, Int. Taxation, Chandigarh

In the result, appeal of the assessee is allowed

ITA 231/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh13 May 2025AY 2018-19

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

For Appellant: Shri Y.K. Sud, CAFor Respondent: Shri Manav Bansal, CIT DR

Section 142(1)Section 144Section 147Section 148

disposed of the objections of the assessee on draft assessment order vide its order dated 08.12.2023. It directed the AO to pass a final assessment order according to the directions of the DRP. The AO, in this way passed the impugned assessment order on 14.12.2023 which is challenged before

M/S. the Rajaji Nagar Housing Co-Operative Society Ltd., Bengaluru vs. Income Tax Officer, Ward-5(2)(3), Bangalore

In the result, the appeal of the assessee is allowed

ITA 89/BANG/2024[2018-19]Status: DisposedITAT Bangalore13 May 2025AY 2018-19

Bench: Shri Waseem Ahmedassessment Year: 2018-19

For Appellant: Shri Mallaharao, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 80ASection 80PSection 80P(2)(d)

view that the phrase "order giving rise to a demand" in Rule 68B should be construed as the final assessment order, determining the tax liability of the assessee with interest, fine, penalty or any other sum. With the commencement of the proceedings under Section ... assessment under section 143(3), is not legally sustainable. Consequently, the demand raised based on the computation sheet, which is inconsistent with the final assessment order, is liable to be set aside. Hence the ground of appeal of the assessee is hereby allowed. 14. In the result, the appeal

Ab Inbev Gcc Services India Private Limited, Bangalore, Karnataka vs. Assistant Commissioner of Income Tax, Circle-1(1)(1), Bangalore

In the result, appeal is allowed for statistical purposes

ITA 1635/BANG/2024[2020-21]Status: DisposedITAT Bangalore13 May 2025AY 2020-21

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.1635/Bang/2024 Assessment Year :2020-21

For Appellant: Shri. Chavali Narayan, CAFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bangalore

Section 143(3)Section 144BSection 153Section 92B

Final order of assessment beyond the outer time limit allowed under Section 153 r.w.s 144C(13) of the Act and thereby the final assessment order dated 28 June 2024 is time barred and liable to be quashed; Part I - Transfer pricing adjustments: 3. That on the facts and in circumstances ... grossly erred in considering the total income at INR 1,27,93,72,180 in the 'Computation sheet' provided with respect to the final assessment order vis-a-vis assessed income of INR 65,59,54,350 determined as per Final order of assessment, thereby resulting in an erroneous adjustment

Toyota Boshoku Automotive India Private Limited, Bidadi vs. Assessment Unit, Income Tax Department Or the DCIT, Circle - 7(1)(1), Koramangala

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

ITA 1539/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore09 May 2025

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri K.R Vasudevan, AdvocateFor Respondent: Ms. Neera Malhotra, CIT (DR)

Section 234ASection 270A

which was disallowed by the CPC while processing the return under section 143(1) of the Act. Further, the AO after passing the final assessment order computed the total tax liability of the assessee and the AO relying on 143(1) intimations also not allowed the claim of the foreign ... levying interest under section 115P of the Act. 39.1 The necessary facts are that the AO in the computation sheet forming part of final assessment order under section 143(3) r.w.s. . IT(TP)A No.1539/Bang/2024 Page 34 of 37 144C(13) of the Act besides computing final income tax liability

Eastspring Investments India Equity Open Limited, Mauritius vs. Deputy Commissioner of Income-Tax - International Taxation Circle 2(2)(1) - Mumbai, Mumbai

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

ITA 1219/MUM/2025[2022-23]Status: DisposedITAT Mumbai09 May 2025AY 2022-23

Bench: Ms. Padmavathy Sshri Sandeep Singh Karhail

For Appellant: Shri Ketan VedFor Respondent: Shri Satya Pal Kumar, CIT(DR)

Section 143(3)Section 144C(3)Section 144C(5)Section 70Section 70(2)

Date of Hearing – 05/05/2025 Date of Order – 09/05/2025 ORDER PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeal against the final assessment order dated 27.12.2024, passed under Section 143(3) r.w. Section 144C(3) of the Income Tax Act, 1961 (“the Act"), pursuant to the directions dated ... income from other sources at the base tax rate of 40% plus surcharge and cess without any justification in the final assessment order. 4. 2. On account of the rejection of the manner of set-off of the losses as adopted by the Appellant and duplication of income, the learned

Quinnox Consultancy Services Limited, Mumbai vs. DCIT, 3(1)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 4299/MUM/2024[2020-21]Status: DisposedITAT Mumbai09 May 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), MS. PADMAVATHY S (Accountant Member)

Section 143(3)

Pronouncement : 09/05/2025 आदेश / O R D E R PER AMIT SHUKLA, JM: The aforesaid appeal has been filed by the assessee against final Assessment order dated 12.07.2024 passed by ld. AO u/s.143(3)/144C(13)/144B of the Income Tax Act, 1961 (in short ... reported before us at the time of hearing. 12. In so far as the Ground No. 1 relating to challenging the limitation of final assessment order dated 12.07.2024 has not been pressed. Therefore, the same is dismissed as not pressed. 13. Ground Nos. 2, 3 & 4 are general in nature

Molvizadah Sons India Private Limited, Delhi vs. DCIT Circle-16(1), Delhi

ITA 5297/DEL/2024[2021-22]Status: HeardITAT Delhi09 May 2025AY 2021-22

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

Section 144C(10)Section 92C

Rs.4.29 Crores were revised to the tune of Rs.1.64 Crores, after the directions of the Ld. DRP. Then, the Assessing Officer passed the final assessment order, which is impugned before us and framed the assessment. 4. Aggrieved with the said order of the Assessing Officer, the assessee has come ... ought to be quashed. 3. On the facts and circumstances of the case, the learned AO has erred in not issuing the final assessment order in conformity with the directions of the Hon'ble DRP. Thus, the learned AO has violated the mandatory provisions of section 144C(10) read with

Janardhan Kapur, Haryana vs. ITO, Ward 29(1), Delhi

The appeal of the assessee is allowed

ITA 4754/DEL/2024[2019-20]Status: DisposedITAT Delhi09 May 2025AY 2019-20

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2019-20 Janardhan Kapur, Vs Ito, C/O Sanjiv Sapra & Associates Llp, Ward-29(1), Chartered Accountants, Delhi. C-763, New Friends Colony, New Delhi – 110 025. Pan: Aojpk8128G (Appellant) (Respondent) Assessee By : Shri Sanjiv Sapra, Fca Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 28.04.2025 Date Of Pronouncement : 09.05.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 13.09.2024 Of The Commissioner Of Income-Tax (Appeals), Nfac, Delhi (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’, For Short) In Appeal No.Nfac/2018-19/10092978 Arising Out Of The Appeal Before It Against The Order Dated 23.09.2021 Passed U/S 143(3) R.W.S. 144B Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By The Assessment Unit, Income-Tax Department (Hereinafter Referred To As The Ld. Ao). 2. On Hearing Both The Sides, We Find That Amongst Other Grounds On Merits The Assessee Has Raised Ground No.2. This Ground Was Not Raised Before The Cit(A). However, Before Us, A Separate Application Is Moved Requesting To Raise This As An Additional Ground. Considering That The Ground No. 2 Questions The Assumption Of Jurisdiction To Pass Final Assessment Order & Can Be Decided On The Basis Of Admitted Facts, The Same Is Admitted. 3. The Ground No.2 As Raised Is Reproduced Below:- “That The Order Passed By The Assessing Officer (Ao) Under Section 143(3)/144B Of The Income-Tax Act, 1961 (Act) Was Without Jurisdiction, Null & Void Since No Prior Draft Assessment Order As Required Under Section 144C(1) Was Passed & Provided To The Appellant Being A Non- Resident & “Eligible Assessee” As Per Section 144C(15)(B)(Ii) Of The Act.”

For Appellant: Shri Sanjiv Sapra, FCAFor Respondent: Shri Om Parkash, Sr. DR

Section 143(3)Section 144CSection 144C(1)Section 144C(15)(b)

moved requesting to raise this as an additional ground. Considering that the ground no. 2 questions the assumption of jurisdiction to pass final assessment order and can be decided on the basis of admitted facts, the same is admitted. 3. The ground No.2 as raised is reproduced below:- “That ... purpose of section 144C the AO was required to first issue a draft assessment order. However, we find that the AO issued a final assessment order u/s 143(3)/144B of the Act and raised the income-tax demand and also initiated penalty proceedings. 5. The ld. DR has defended

Iqor India Services Private Limited, Delhi vs. Deputy Commissioner of Income-Tax, Delhi

In the result ground number 2 is allowed and Grounds no

ITA 3114/DEL/2024[AY 2020-21]Status: HeardITAT Delhi09 May 2025

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh[Assessment Year: 2020-21]

assessee drawn the attention of the Bench towards the assessment order and pointed out that the Assessing Officer while passing the final assessment order has sustained the addition of Rs.3,84,06,821/- ignoring the directions of the DRP as well as the order giving effect

Nxp India P.Ltd(Successor of Nxp Semiconductors India P.Ltd), New Delhi vs. ACIT, Circle-18(2), New Delhi

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

ITA 8341/DEL/2018[2014-15]Status: DisposedITAT Delhi09 May 2025AY 2014-15

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh[Assessment Year: 2014-15]

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

Assessing Officer. The Ld. DRP reduced the TP adjustments to the tune of Rs.21,04,63,247/-. Thereafter, the Assessing Officer passed the final assessment order. 4. Aggrieved with the order of the Assessing Officer, the assessee has come up in appeal before us by raising the following grounds

Nxp India P.Ltd(Formerly Known As Freescale Semiconductor India Pvt. Ltd), New Delhi vs. JCIT Range-3, New Delhi

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

ITA 5763/DEL/2017[2013-14]Status: DisposedITAT Delhi09 May 2025AY 2013-14

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh[Assessment Year: 2013-14]

Section 142(1)Section 143(1)Section 143(2)Section 234ASection 92Section 92C

much as the TPO has reduced the adjustment from Rs.9.45 Crores to 8.91 Crores. Thereafter, the Assessing Officer passed the final assessment order after making the additions of Rs.8.91 Crores to the income of the assessee. 4. Aggrieved with the said order, the assessee has come up in appeal before

Asstt Commissioner of Income Tax, Circle - 1(1), Rajkot vs. Symbosa Granito Private Limited, Wankaner

ITA 806/RJT/2024[2016-17]Status: DisposedITAT Rajkot08 May 2025AY 2016-17

Bench: Dr. Arjun Lal Saini. & Dinesh Mohan Sinhaआयकर अपीलसं./Ita No.806/Rjt/2024 निर्धारणवर्ष / Assessment Year: (2016-17) (Hybrid Hearing) Asstt. Commissioner Of Income Vs. Symbosa Granite Pvt. Limited, Tax, Circle - 1(1), Rajkot Room No. 502,Aaykar Bhavan, Survey No. 125P1/P2,126,131P1/P2/P3, Race Course Road, Village- Matel, Rajkot - 300001 Wankaner- 363621(Gujarat) (Assessee) (Respondent) Assessee By : Shri Mehul Ranpura, Ld. Ar Respondent By : Shri Sanjay Pungliya, Ld. Cit (Dr) Date Of Hearing : 14/02/2025 Date Of Pronouncement : 08/05/2025 आदेश/ Order Per Bench: Captiond Appeal Filed By The Revenue, Pertaining To Assessment Year (Ay) 2016-17, Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax(Appeals), Dated 13.08.2024,Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer, Under Section 143(3) R.W.S. 263 & 144B Of The Income Tax Act, 1961, Vide Order Dated 31.03.2022.

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Sanjay Pungliya, Ld. CIT (DR)

Section 139(1)Section 143(3)Section 144BSection 263Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER. & DINESH MOHAN SINHA, JUDICIAL