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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

Shri Bharatbhushan Kishanlal Gupta, Gandhidham vs. The ITO- International Taxation, Gandhidham

In the result, the appeal is allowed in the terms indicated above

ITA 269/RJT/2019[2017-18]Status: DisposedITAT Rajkot08 May 2025AY 2017-18

Bench: Dr. Arjun Lalsaini. & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 269/Rjt/2019 (Assessment Year: 2017-18) (Hybrid Hearing) Bharatbhushan Kishanlal Vs. The Income Tax Officer, Gupta, (International Taxation) Prop. Of Aqua Shipping, Suit - Gandhidham – 370210 100, Grain Merchant Association Bldg., 2Nd Floor, Plot No. 297, Wd – 12B, Gandhidham – 370001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afcpg3849N (अपीलाथ"/Assessee) (""यथ"/Respondent)

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr. DR
Section 144CSection 172Section 172(4)Section 172(5)Section 234ASection 271(1)(c)

Petitioner had a statutory remedy available to it. 45. For the above reasons, the draft assessment order dated 28th March, 2014 and the final assessment order dated 28th January, 2015 passed by the AO are held to be void ab initio and quashed on that basis. The orders consequential thereto ... Assessing Officer should have passed the draft assessment order which has not been done in the present case. Thus, the final assessment order passed by the Assessing Officer without proposing the draft assessment order is against the scheme of the Act and in complete violation of the mandate of section

Atul Limited, Ahmedabad vs. The ACIT, Circle-1(1)(1), Ahmedabad

In the result, the appeal is partly allowed

ITA 38/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad08 May 2025AY 2017-18

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Atul Limited Acit, Cir.1(1)(1) Atul House, Gi Patel Mark Vs Ahmedabad. Mithila Society, Ahmedabad. Pan : Aabca 2390 M (Applicant) (Responent) Assessee By : Shri Bandish Soparkar, Ar : Shri Prathvi Raj Meena, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 01/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/05/2025 आदेश/O R D E R आदेश आदेश आदेश

For Appellant: Shri Bandish Soparkar, AR
Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 35Section 40Section 9(1)(vii)Section 92C

आदेश/O R D E R आदेश आदेश आदेश PER MAKARAND V.MAHADEOKAR, AM: This appeal filed by the assessee is directed against the final assessment order dated 26.08.2022 passed under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 [hereinafter referred ... assessee raised objections before the Hon’ble DRP, which issued directions under section 144C(5) on 16.06.2022. Thereafter, the Assessing Officer passed the final assessment order dated 26.08.2022 under section 143(3) r.w.s. 144C(13), determining total income at Rs.178,23,60,063/- as against the returned income of Rs.168

Kony Inc, United States of America vs. Deputy Commissioner of Income Tax, International Taxation 1(2), Chennai, Tamil Nadu

In the result, the appeal filed by the assessee is allowed and the stay petition filed by the assessee is dismissed

ITA 185/CHNY/2025[2022-23]Status: DisposedITAT Chennai08 May 2025AY 2022-23

Bench: Shri George George K & Shri Jagadish

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri V. Justin, CIT
Section 143(2)Section 4

GEORGE GEORGE K, VICE PRESIDENT: This appeal at the instance of the assessee is directed against the final assessment order dated 16.12.2024 passed under section ITA No.185/CHNY/2025 & SA No.25/CHNY/2025 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year ... draft assessment order was confirmed by the DRP in its directions dated 29.11.2024. Pursuant to the DRP’s direction, the impugned final assessment order was passed on 16.12.2024. 4. Aggrieved by the impugned final assessment order, the assessee has filed the present appeal raising seven grounds and various sub-grounds

Here Solutions India Private Limited, Mumbai vs. Assistant Commissioner of Income-Tax, Circle 10 (1)(1), Mumbai

In the result, the appeal of the asessee bearing ITA No

ITA 5918/MUM/2024[2014-15]Status: DisposedITAT Mumbai08 May 2025AY 2014-15

Bench: Shrianikesh Banerjee () & Shri Girish Agrawal ()

Section 143(3)Section 144C(3)Section 250Section 92D

made as compared to the order under section 92CA(3) amount to Rs.2,95,65,692/- for the I.T. services segment. Finally, in final assessment order, said addition was made and the same was confirmed in appeal. Related to this company as comparable, the assessee prayed for deletion

American Chemical Society, Usa vs. DCIT (International Tax), Circle 1(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1160/MUM/2024[2013-14]Status: DisposedITAT Mumbai08 May 2025AY 2013-14

Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)

Section 143(2)Section 144C(13)Section 147Section 148ASection 234ASection 250Section 271(1)(c)Section 9(1)(vi)

assessment years, the objections so raised by the assessee were dismissed. 6. Thereafter, following the directions of the DRP, the AO passed the final assessment order u/s. 147 r.w.s 144C(13) of the Act vide order dated 19.01.2024 wherein amount of Rs. 46,14,79,249/- was brought

Biogenex Life Sciences Private Limited, Hyderabad vs. DCIT, Circle 1(1), Hyderabad

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

ITA 68/HYD/2022[2017-18]Status: DisposedITAT Hyderabad07 May 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: : Smt. M. Narmada, CIT-DR
Section 143(3)Section 92C

आदेश/ORDER PER MADHUSUDAN SAWDIA, A.M.: This appeal is filed by M/s. Biogenex Life Sciences Private Limited (“the assessee"), feeling aggrieved with the final assessment order of Learned Assessing Officer (“Ld. AO”) passed u/s. 143(3) r.w.s. 144C(13) & 144B of the Income ... undertaken with AE. 7. The Ld. AO/TPO/DRP erred in not considering the Brought Forward losses of Rs. 80,05,365/- while passing the Final Assessment Order dated 27.01.2022. 8. The Ld. AO/TPO/DRP erred in not considering the Unabsorbed Depreciation and allowance of Rs. 1,87,83,938/-under section

Tata Consumer Products Limited, Kolkata vs. D.C.I.T., Circle-4(1), Kolkata

In the result, both the appeals of the assessee are allowed

ITA 426/KOL/2022[2018-2019]Status: DisposedITAT Kolkata07 May 2025AY 2018-2019

Bench: Shri George Mathan & Shri Sanjay Awasthi

For Appellant: Shri Ram Sehadri, CAFor Respondent: Shri Praveen Kishore, CIT, DR
Section 144C(13)Section 144C(5)Section 153Section 153B

case of the assessee that the directions had been uploaded on 31.01.2022 and hence the limitation for passing of a final assessment order had expired by 28.02.2022, whereas, it is the case of the Assessing Officer that the directions of the DRP had been received on 03.02.2022 and hence ... Section 144C(13) of the Act. ………………………. 18. The sole issue to be decided is the point of initiation of limitation for passing a Final Assessment Order. Section 144C is entitled 'Reference to dispute resolution panel' and sets out the procedure for assessment in cases involving international transactions. The procedure contemplated

Tata Consumer Products Limited (Erstwhile Tata Global Beverages Limited), Kolkata vs. D.C.I.T., Circle-4(1), Kolkata

In the result, both the appeals of the assessee are allowed

ITA 385/KOL/2022[2017-2018]Status: DisposedITAT Kolkata07 May 2025AY 2017-2018

Bench: Shri George Mathan & Shri Sanjay Awasthi

For Appellant: Shri Ram Sehadri, CAFor Respondent: Shri Praveen Kishore, CIT, DR
Section 144C(13)Section 144C(5)Section 153Section 153B

case of the assessee that the directions had been uploaded on 31.01.2022 and hence the limitation for passing of a final assessment order had expired by 28.02.2022, whereas, it is the case of the Assessing Officer that the directions of the DRP had been received on 03.02.2022 and hence ... Section 144C(13) of the Act. ………………………. 18. The sole issue to be decided is the point of initiation of limitation for passing a Final Assessment Order. Section 144C is entitled 'Reference to dispute resolution panel' and sets out the procedure for assessment in cases involving international transactions. The procedure contemplated

Akshay Kumar Rungta, Bangalore vs. Income Tax Officer, Ward 2(1), International Taxation

In the result, appeal filed by the assessee is allowed as per above terms

ITA 66/BANG/2024[2015-16]Status: DisposedITAT Bangalore07 May 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

For Appellant: Shri. Ravishankar S. V, AdvocateFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 10(38)Section 143(3)Section 144CSection 147Section 147rSection 148Section 151Section 153Section 153CSection 250

raise objections before the DRP against any variation proposed to the income or loss which can be prejudicial to the assessee. Only the final Assessment Order which results in enforceable demand against the assessee. Thus, in strict sense, the term draft Assessment Order cannot be treated as Assessment Order passed ... section 144C(13) of the Act. Therefore, the non-signing of the draft Assessment Order forwarded to the assessee would not invalidate the final Assessment Order passed IT(IT)A No.66/Bang/2024 Page 11 of 31 under section 143(3) r.w.s. 144C(13) of the Act. Here in the case

Shri. Anantula Vijay Mohan, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-6(1)(1), Bangalore

ITA 2060/BANG/2024[2017-18]Status: DisposedITAT Bangalore07 May 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

Section 143(3)Section 250

ITA No.2059 & 2060/Bang/2024 & SP 67/Bang/2024 Anantula Vijay Mohan, Hyderabad IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH: BANGALORE BEFORE SHRI

Anantula Vijay Mohan, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-6(1)(1), Bangalore

ITA 2059/BANG/2024[2016-17]Status: DisposedITAT Bangalore07 May 2025AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

For Respondent: Sri Padma Khincha, A.R
Section 143(3)Section 250

ITA No.2059 & 2060/Bang/2024 & SP 67/Bang/2024 Anantula Vijay Mohan, Hyderabad IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH: BANGALORE BEFORE SHRI

Dsm Shared Services India Private Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

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

ITA 501/HYD/2022[2018-19]Status: DisposedITAT Hyderabad05 May 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Aliasgar Rampurawala, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 43B

/ORDER PER MADHUSUDAN SAWDIA, A.M. : This appeal is filed by M/s. DSM Shared Services India Pvt. Ltd. (“the assessee”), feeling aggrieved with the final assessment order of Learned Assessing Officer ("Ld. AO") passed u/s.143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 ('the Act'), as per the direction ... Pricing (“TP”) adjustment of Rs.6,03,14,533/- and addition u/s. 43B of the Act for Rs.36,85,500/-. 6. Aggrieved with the final assessment order of Ld. AO, the assessee is in appeal before us. At the outset, the Learned Authorised Representative (“Ld. AR”) submitted that, ground nos.1

Gainsight Software Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle 2(1), Hyderabad

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

ITA 200/HYD/2021[2016-17]Status: DisposedITAT Hyderabad05 May 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Aliasgar Rampurawala, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 271ASection 37(1)Section 438

05/05/2025 a CRI/ORDER PER MADHUSUDAN SAWDIA, A.M. : This appeal is filed by M/s. Gainsight Software Pvt. Ltd. (“the assessee”), feeling aggrieved with the final assessment order of Learned Assessing Officer ("Ld. AO") passed u/s.143(3) r.w.s. 144C(13),143(3A) & 143(3B) of the Income ... para 4 to the said Circular. 14. On the facts and in the circumstances of the case and in law, the final assessment order dated 30 March 2021 under section 143(3) read with section 144C (13) of the Act passed by National e-Assessment Centre, Delhi, pursuant to invalid

Open Text Technologies India Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad

ITA 2387/HYD/2018[2014-15]Status: DisposedITAT Hyderabad05 May 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Madhusudan Sawdia, Hon'Ble

For Appellant: Revenue byFor Respondent: Date of hearing
Section 143(3)Section 92B

ORDER PER MADHUSUDAN SAWDIA, A.M. : This appeal is filed by M/s. Open Text Technologies India Private Limited (“the assessee”), feeling aggrieved with the final assessment order of Learned Assessing Officer (“Ld. AO”) passed u/s. 143(3) rws 92CA(3) & 144(C)(1) of the Income ... assessment on 29.10.2018 by making total addition of Rs.16,21,20,521/- on account of upward adjustment of ALP. 6. Aggrieved with the final assessment order of Ld. AO, the assessee is in appeal before us. 7. At the outset, Ld. AR submitted that they are not pressing ground Nos.1

Swapan Bhttacharya, Kolkata vs. ACIT, Circle 61, Kolkata

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

ITA 242/KOL/2025[2017-18]Status: DisposedITAT Kolkata05 May 2025AY 2017-18

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 139(1)Section 143(2)Section 143(3)Section 250Section 90

present case. In the present case, the returns were filed without FTC, however the same was filed before passing of the final assessment order. The filing of FTC in terms of the Rule 128 is only directory in nature. The rule is only for the I.T.A. No.: 242/KOL/2025 Assessment Year ... petitioner on 02.02.2021. 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 wade only to the extent of disallowing of FTC clam made by the petitioner

Wns Global Services Private Limited, Mumbai vs. Asessment Unit, National Faceless Assessment Centre, New Delhi

In the result, the appeal of the assessee bearing ITA No

ITA 4432/MUM/2024[AY 2020-2021]Status: DisposedITAT Mumbai05 May 2025

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarwns Global Services Private Vs Assessment Unit, National Faceless Limited, Mumbai Assessment Centre, New Delhi Pl-10/11, Gate No.4, Godrej- Boyce Complex, Pirojshanagar, L.B.S.Marg, Vikhroli (West), Mumbai-400 079 Pan: Aaacw2598L Appellant Respondent

For Appellant: ShriPorus Kaka A/w Manish KanthFor Respondent: Shri Pankaj Kumar (CIT DR)
Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 253

29/04/2025 Date of pronouncement : 05/05/2025 O R D E R Per Anikesh Banerjee (JM): This appeal of the assessee is directed against the final assessment order passed by the Assessment Unit, Income-tax Department (for brevity the “Ld.AO”) under section 143(3) read with section 144C(13) read with section ... Income-tax Act, 1961 ('Act') against the order passed by the Assessment Unit, National Faceless Assessment Centre ('AO') dated 18 June 2024 ('Final Assessment order") in pursuance of the directions issued by Dispute Resolution Panel-2 (DRP), Mumbai dated 3 May 2024 (DRP Directions") on the following grounds which

International Seaport Dredging Limited, Chennai vs. DCIT, Chennai

The appeal stand allowed

ITA 72/CHNY/2018[2013-14]Status: DisposedITAT Chennai02 May 2025AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकर अपील सं./ Ita No.72/Chny/2018 (िनधा)रणवष) / Assessment Year: 2013-14) & आयकर अपील सं./ It (Tp)A No.35/Chny/2018 (िनधा)रणवष) / Assessment Year: 2014-15) & आयकर अपील सं./ It (Tp)A No.87/Chny/2019 (िनधा)रणवष) / Assessment Year: 2015-16) M/S. International Seaport Dredging Dcit / Jcit(Osd) Private Limited, Corporate Circle-2(2) बनाम 5Th Floor, Challam Towers, Chennai. Old No.62, New No.113, / Vs. Dr.Radhakrishnan Salai Chennai-600 004. "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aabci-2286-E (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Ashik Shah (C.A) – Ld.Ar ""थ"कीओरसे/Respondent By : Shri A.Sasi Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 05-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 02-05-2025 आदेश / O R D E R Per Manu Kumar Giri, Jm: These Appeals By Assessee For Assessment Years (Ay) 2013-14 & 2014-15 Arise Out Of The Separate Orders Of Assessments Framed By Ld.

For Appellant: Shri Ashik Shah (C.A) – Ld.ARFor Respondent: Shri A.Sasi Kumar (CIT) -Ld. DR
Section 143(3)

upholding the other adjustments made by the TPO and AO. 2. For the AY 2015-16, the Appellant filed an appeal against the final assessment order before the CIT(A), who upheld the order of the AO and TΡΟ. The adjustments made during ... while computing the total income of the Appellant without providing any basis or the reason for such disallowance in the final assessment order. The assessee submitted that the Appellant, had in line with the Accounting Standard ('AS') 7 notified by the Ministry of Corporate Affairs ('MCA') after consultation with

Ntt Docomo, Inc., Mumbai vs. ACIT (International Taxation), Circle-3(3)(1)

In the result, appeal of the assessee is allowed on legal grounds

ITA 2736/MUM/2024[2014-15]Status: DisposedITAT Mumbai02 May 2025AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI VIKRAM SINGH YADAV (Accountant Member)

Section 147Section 148Section 148ASection 9(1)(vii)

Pronouncement 02/05/2025 आदेश / O R D E R PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the assessee against final assessment order dated 20/03/2024 passed u/s.147 / 144C(13) for the A.Y.2014-15 in pursuance of direction given by the DRP dated 22/02/2024. 2. In various grounds of appeal

Farfetch India Private Limited, Delhi vs. Income Tax Officer, National Faceless Assessment, Delhi

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

ITA 5555/DEL/2024[AY 2021-22]Status: DisposedITAT Delhi02 May 2025

Bench: Shri Mahavir Singh & Shri Pradip Kumar Kedia[Assessment Year : 2021-22] Farfetch India Pvt.Ltd. Vs Ito 333, 3Rd Floor, Devika Tower 6 National Faceless Nehru Place, South Delhi Assessment Centre New Delhi-110019 Delhi Pan-Aadcf3785H Appellant Respondent Appellant By None Respondent By Shri Rajesh Dhanesta, Sr.Dr Date Of Hearing 02.05.2025 Date Of Pronouncement 02.05.2025 Order

Section 143(3)

Pronouncement 02.05.2025 ORDER PER PRADIP KUMAR KEDIA, AM : The captioned appeal has been filed at the instance of the assessee against the final assessment order dated 30.10.2024 passed u/s 143(3) r.w.s 144C(13) r.w.s 144B of the Act pertaining to assessment year 2021-22 in pursuance of direction

Atotech India Pvt. Ltd., Gurgaon vs. DCIT, Gurgaon

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

ITA 6571/DEL/2016[2012-13]Status: HeardITAT Delhi02 May 2025AY 2012-13

Bench: Shri Mahavir Singh & Shri Manish Agarwalatotech India Private Dy. Cit, Limited, Circle-1(1), 66 Km Stone, Nh-8, Delhi Vs. Gurgaon. Jaipur Highway, Gurgaon. (Appellant) (Respondent)

apply 7.84% rate (Libor plus 300 basis points) and the final addition was reduced to Rs. 3,19,174/- in the final assessment order. 7. Before us, ld.AR of the assessee argued that the assessee being entrepreneur, assumes all entrepreneurial functions and risk and earns entrepreneurial returns and the receivables