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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

Knauf India Pvt Ltd (Earlier Know As Usg Boral Building Products (India) Pvt Ltd), Gurgaon vs. ITO, Ward-14(3), New Delhi

In the result, the appeal filed by the assessee being ITA

ITA 2061/DEL/2022[2018-19]Status: DisposedITAT Delhi21 Mar 2025AY 2018-19

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajit Kumar Jain, CAFor Respondent: Shri S.K. Jhadav, CIT DR
Section 144Section 37Section 92CSection 92C(3)Section 92D

Date of Order : 21.03.2025 O R D E R PER S.RIFAUR RAHMAN, AM : 1. These appeals are filed by the assessee against the final assessment order dated 30.06.2022 passed u/s 144 r.w.s.144C (13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’) subsequent to the directions ... consideration and thereafter passing a speaking order, which is in gross violation of section I 44C(8) of the Act and thus, the final assessment order passed for the relevant A Y is bad in law. Transfer Pricing Grounds: A. Erroneous adjustment of INR 73,389,756 relating to transfer

Knauf India Pvt Ltd (Earlier Know As Usg Boral Building Products (India) Pvt Ltd), Haryana vs. ITO, Ward 14 (3), New Delhi

In the result, the appeal filed by the assessee being ITA

ITA 2060/DEL/2022[2017-18]Status: DisposedITAT Delhi21 Mar 2025AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajit Kumar Jain, CAFor Respondent: Shri S.K. Jhadav, CIT DR
Section 144Section 37Section 92CSection 92C(3)Section 92D

Date of Order : 21.03.2025 O R D E R PER S.RIFAUR RAHMAN, AM : 1. These appeals are filed by the assessee against the final assessment order dated 30.06.2022 passed u/s 144 r.w.s.144C (13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’) subsequent to the directions ... consideration and thereafter passing a speaking order, which is in gross violation of section I 44C(8) of the Act and thus, the final assessment order passed for the relevant A Y is bad in law. Transfer Pricing Grounds: A. Erroneous adjustment of INR 73,389,756 relating to transfer

At & T Global Network Services India Private Ltd., Gurgaon vs. ACIT Circle-1(1), New Delhi

ITA 1576/DEL/2022[2018-19]Status: DisposedITAT Delhi21 Mar 2025AY 2018-19

Bench: Sh. Satbeer Singh Godara & Sh. Avdhesh Kumar Mishra

For Appellant: Sh. K. M. Gupta, Adv. &For Respondent: Sh. Dharm Veer Singh, CIT-DR
Section 143(3)

425/Del/2024 AT&T Global Network Services India Pvt. Ltd. 3. This assessee’s appeal ITA No. 1576/Del/2022 raises the following substantive grounds: “1. Final assessment order is void-ab-initio On the facts and circumstances of the case and in law, the final assessment order dated 28 May 2022 passed ... initiating penalty proceedings under section 270A of the Act against the Appellant on account of the above adjustments made in the impugned final assessment order dated 28 May 2022.” 4. Learned counsel submits first of all that the assessee’s first substantive issue is general in nature. Rejected in very

Oceaneering International Gmbh, Mumbai vs. Deputy Commissioner of Income Tax (It) 3(2)(2), Air India Building, Mumbai

In the result, ground no. 2 of the assessee's appeal is allowed

ITA 4670/MUM/2023[AY 2021-22]Status: DisposedITAT Mumbai21 Mar 2025

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

Section 143(2)Section 143(3)Section 153Section 234ASection 234BSection 234CSection 274Section 44B

referred to as 'the DRP'). 2. Aggrieved assessee has filed present appeal against the impugned order on the following grounds of appeal: “1. Final Assessment order barred by limitation 1. 1. The Appellant submits that considering the facts and circumstances of its case and the law prevailing on the subject ... barred by limitation and hence, ought to be struck down. 1. 2. The Id. AO erred in not appreciating that timelines for passing final assessment order as per Section 153 of the Act being 12 months from the end of relevant AY 2021-22 was 31 March 2023. Accordingly

Anoosha Paruchuri, Hyderabad vs. Income Tax Officer, Ward-2, Karimnagar

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

ITA 145/HYD/2025[2021-22]Status: DisposedITAT Hyderabad20 Mar 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: A. Sharren, AdvocateFor Respondent: : Shri Suresh Babu, SR-DR
Section 139(1)Section 143(1)Section 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 implementation of the provisions ... 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 aside only to the extent of disallowing ITA No.145/Hyd/2025 5 of FTC claim made

(Late) Laxman Rao Banapuram Rep by L/R B Rama Devi, Hyderabad vs. DCIT, Circle-14(1), Hyderabad

In the result appeal of the assessee for the assessment year 2017-2018 is dismissed

ITA 603/HYD/2022[2017-18]Status: DisposedITAT Hyderabad20 Mar 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA KA Sai PrasadFor Respondent: Shri Srinath Sadanala, Sr. AR
Section 132Section 142Section 153ASection 54F

then, the Assessing Officer will not get extended time limit for completion of assessment as per sec.153A) of the Act and consequently, the final assessment orders passed by the Assessing Officer for the assessment years 2014-2015 and 2015-2016 are barred by limitation and thus, we quash the assessment

(Late) Laxman Rao Banapuram, Rep by L/R B Rama Devi, Hyderabad vs. DCIT, Circle-14(1), Hyderabad

In the result appeal of the assessee for the assessment year 2017-2018 is dismissed

ITA 602/HYD/2022[2015-16]Status: DisposedITAT Hyderabad20 Mar 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA KA Sai PrasadFor Respondent: Shri Srinath Sadanala, Sr. AR
Section 132Section 142Section 153ASection 54F

then, the Assessing Officer will not get extended time limit for completion of assessment as per sec.153A) of the Act and consequently, the final assessment orders passed by the Assessing Officer for the assessment years 2014-2015 and 2015-2016 are barred by limitation and thus, we quash the assessment

(Late) Laxman Rao Banapuram Rep by L/R B Rama Devi, Hyderabad vs. DCIT-Circle-14(1), Hyderabad

In the result appeal of the assessee for the assessment year 2017-2018 is dismissed

ITA 601/HYD/2022[2014-15]Status: DisposedITAT Hyderabad20 Mar 2025AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA KA Sai PrasadFor Respondent: Shri Srinath Sadanala, Sr. AR
Section 132Section 142Section 153ASection 54F

then, the Assessing Officer will not get extended time limit for completion of assessment as per sec.153A) of the Act and consequently, the final assessment orders passed by the Assessing Officer for the assessment years 2014-2015 and 2015-2016 are barred by limitation and thus, we quash the assessment

Timirbaran Mazumder, Kolkata vs. D.C.I.T./A.C.I.T., Circle 2(1), International Taxation, Kolkata

The appeal are allowed

ITA 1905/KOL/2024[2018-19]Status: DisposedITAT Kolkata20 Mar 2025AY 2018-19

Bench: Shri George Mathan & Shri Rakesh Mishra

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

present case. In the present case, the returns were filed without FIC, 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 implementation of the provisions ... Mazumder. the 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

Credit Agricole Corporate and Investment Bank, Mumbai vs. The Dy-CIT (Int. Taxation)-2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 749/MUM/2022[2017-18]Status: DisposedITAT Mumbai20 Mar 2025AY 2017-18

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

order of the TPO and the final assessment of the AO. The assessee through one of the additional grounds contended the validity of final assessment order passed under section 143(3) r.w.s.144C by relying on the decision of the Hon'ble Madras High Court in the case of Roca Bathroom ... submitted that the said additional ground is not pressed for admission. Accordingly, the additional ground raised by the assessee with regard to the final assessment order being barred by limitation is not admitted for adjudication. 7. The assessee vide letter dated 24.05.2023 raised an additional ground stating that the order

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Dy.CIT of Income Tax (Internationsl Taxation) -2(1) (1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1234/MUM/2022[2018-19]Status: DisposedITAT Mumbai20 Mar 2025AY 2018-19

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

order of the TPO and the final assessment of the AO. The assessee through one of the additional grounds contended the validity of final assessment order passed under section 143(3) r.w.s.144C by relying on the decision of the Hon'ble Madras High Court in the case of Roca Bathroom ... submitted that the said additional ground is not pressed for admission. Accordingly, the additional ground raised by the assessee with regard to the final assessment order being barred by limitation is not admitted for adjudication. 7. The assessee vide letter dated 24.05.2023 raised an additional ground stating that the order

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Jt CIT (International Taxationa), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1027/MUM/2021[2016-17]Status: DisposedITAT Mumbai20 Mar 2025AY 2016-17

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

order of the TPO and the final assessment of the AO. The assessee through one of the additional grounds contended the validity of final assessment order passed under section 143(3) r.w.s.144C by relying on the decision of the Hon'ble Madras High Court in the case of Roca Bathroom ... submitted that the said additional ground is not pressed for admission. Accordingly, the additional ground raised by the assessee with regard to the final assessment order being barred by limitation is not admitted for adjudication. 7. The assessee vide letter dated 24.05.2023 raised an additional ground stating that the order

Credit Agricole Corporate and Investment Bank, Mumbai vs. ACIT (It) 2 (1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 458/MUM/2019[2014-15]Status: DisposedITAT Mumbai20 Mar 2025AY 2014-15

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

order of the TPO and the final assessment of the AO. The assessee through one of the additional grounds contended the validity of final assessment order passed under section 143(3) r.w.s.144C by relying on the decision of the Hon'ble Madras High Court in the case of Roca Bathroom ... submitted that the said additional ground is not pressed for admission. Accordingly, the additional ground raised by the assessee with regard to the final assessment order being barred by limitation is not admitted for adjudication. 7. The assessee vide letter dated 24.05.2023 raised an additional ground stating that the order

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 4652/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Mar 2025AY 2013-14

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent)

Section 143(3)

order of the TPO and the final assessment of the AO. The assessee through one of the additional grounds contended the validity of final assessment order passed under section 143(3) r.w.s.144C by relying on the decision of the Hon'ble Madras High Court in the case of Roca Bathroom ... submitted that the said additional ground is not pressed for admission. Accordingly, the additional ground raised by the assessee with regard to the final assessment order being barred by limitation is not admitted for adjudication. 7. The assessee vide letter dated 24.05.2023 raised an additional ground stating that the order

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 2313/MUM/2017[2012-13]Status: DisposedITAT Mumbai20 Mar 2025AY 2012-13

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank’) 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) 2

Section 143(3)

order of the TPO and the final assessment of the AO. The assessee through one of the additional grounds contended the validity of final assessment order passed under section 143(3) r.w.s.144C by relying on the decision of the Hon'ble Madras High Court in the case of Roca Bathroom ... submitted that the said additional ground is not pressed for admission. Accordingly, the additional ground raised by the assessee with regard to the final assessment order being barred by limitation is not admitted for adjudication. 7. The assessee vide letter dated 24.05.2023 raised an additional ground stating that the order

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1273/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Credit Agricole Corporate & Investment Bank, Vs. 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Appellant) Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

order of the TPO and the final assessment of the AO. The assessee through one of the additional grounds contended the validity of final assessment order passed under Section 143(3) r.w.s.144C by relying on the decision of the Hon'ble Madras High Court in the case of Roca Bathroom ... submitted that the said additional ground is not pressed for admission. Accordingly, the additional ground raised by the assessee with regard to the final assessment order being barred by limitation is not admitted for adjudication. 7. The assessee vide letter dated 24.05.2023 raised an additional ground stating that the order

DCIT (It) 2(1)(1), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1165/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

order of the TPO and the final assessment of the AO. The assessee through one of the additional grounds contended the validity of final assessment order passed under Section 143(3) r.w.s.144C by relying on the decision of the Hon'ble Madras High Court in the case of Roca Bathroom ... submitted that the said additional ground is not pressed for admission. Accordingly, the additional ground raised by the assessee with regard to the final assessment order being barred by limitation is not admitted for adjudication. 7. The assessee vide letter dated 24.05.2023 raised an additional ground stating that the order

ADIT (It) 1(2), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1839/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

order of the TPO and the final assessment of the AO. The assessee through one of the additional grounds contended the validity of final assessment order passed under section 143(3) r.w.s.144C by relying on the decision of the Hon'ble Madras High Court in the case of Roca Bathroom ... submitted that the said additional ground is not pressed for admission. Accordingly, the additional ground raised by the assessee with regard to the final assessment order being barred by limitation is not admitted for adjudication. 7. The assessee vide letter dated 24.05.2023 raised an additional ground stating that the order

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1479/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank’) 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent)

Section 143(3)

order of the TPO and the final assessment of the AO. The assessee through one of the additional grounds contended the validity of final assessment order passed under section 143(3) r.w.s.144C by relying on the decision of the Hon'ble Madras High Court in the case of Roca Bathroom ... submitted that the said additional ground is not pressed for admission. Accordingly, the additional ground raised by the assessee with regard to the final assessment order being barred by limitation is not admitted for adjudication. 7. The assessee vide letter dated 24.05.2023 raised an additional ground stating that the order

Vanshika Motors (P) Ltd., Meerut vs. ACIT, Circle- 2, Meerut

Appeals of the assessee are allowed

ITA 6214/DEL/2017[2010-11]Status: DisposedITAT Delhi20 Mar 2025AY 2010-11

Bench: Shri Mahavir Singh(), Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

For Appellant: Sh. Ruchesh Sinha, AdvFor Respondent: Sh. T. James Singson, CIT, DR
Section 11Section 127Section 132Section 139(1)Section 153ASection 153DSection 274

Assessing Officer in terms of Section 144A of the Act. She stated that even the Additional CIT/JCIT is involved in the preparation of final assessment order by way of instructing the Assessing Officer issuing final show cause notice. She referred to Paragraph 3.2 of the Manual, which reads as under