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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

Pallavi Pal, Noida vs. Ward 5(2)(1), Noida, Aayakar Bhawan, Gautam Budh Nagar

Accordingly, Revenue’s appeal in this case is dismissed

ITA 4657/DEL/2024[2012-13]Status: DisposedITAT Delhi06 Jan 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Krinwant Sahayita No.4657/Del/2019 (Assessment Year 2008-09) Income Tax Officer, Shri Vijay Shankar Ward-66(4), Bajpai, New Delhi. Vs. 104, Riico Ind. Area, School Of Aeronautics Delhi Jaipur Highway, Neemrana, Rajsthan-301705. Pan-Aeppb6550D (Appellant) (Respondent) Assessee By Shri Rahul Bardia, Ca Department By Ms. Harpreet Kaur, Sr. Dr Date Of Hearing 19/08/2025 Date Of Pronouncement 25/08/2025

Section 147Section 148Section 253(2)Section 271Section 271(1)(c)

Appeals) has grossly erred in holding that assessee has not received any notice from the department till the passing of final Assessment order because during the assessment proceedings all notices were served upon the assessee well in time as per the provisions of the IT act on the addresses available

Anshit Builders and Home Fin Co. Pvt. Ltd., Delhi vs. Income Tax Officer, Ward 2(4), New Delhi, Delhi

In the result, all the appeals of the assessee are allowed and all 7

ITA 2604/DEL/2024[2017-18]Status: DisposedITAT Delhi06 Jan 2025AY 2017-18

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri V. K. Sabharwal, AdvFor Respondent: Shri Jitender Singh, CIT DR
Section 153ASection 153DSection 281B

examine the approval dated 27.09.2021, we find that in para 3, the ld. competent authority has mentioned as follows:- “3. Copies of the final assessment orders should be forwarded to this office immediately after passing the orders. Proposal for retention of seized material should also be forwarded to this office

Sms Concast Ag, Delhi vs. ACIT Circle-3(1)(2) International Taxation, Delhi

In the result, the appeal of the assessee is allowed

ITA 1444/DEL/2022[2017-18]Status: DisposedITAT Delhi06 Jan 2025AY 2017-18

Bench: Shri Ramit Kochar & Shri Sudhir Kumar

For Appellant: Sh. Rohit Jain, AdvocateFor Respondent: Sh. Abhishek Deval, Sr. DR
Section 271(1)Section 271(1)(c)Section 80Section 80GSection 80HSection 80I

facts of the case in dismissing the ground that the penalty order passed is void ab-initio in the absence of passing of final assessment order in terms of the directions of the Honorable members of the ITAT. 9. That the appellant craves your honour's leave to add, alter

ACIT, Circle-7(1), Kolkata vs. Hi Tech Systems and Services Limited, Kolkata

In the result, both the appeals of the assessee are allowed and both the appeals of the revenue are dismissed

ITA 1318/KOL/2024[2022-2023]Status: DisposedITAT Kolkata06 Jan 2025AY 2022-2023

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri J.P. Khaitan &For Respondent: Shri Subhendu Datta, DR
Section 143(3)Section 147Section 148Section 148(2)Section 151Section 153Section 80H

petition before the Hon'ble Calcutta High Court and Hon'ble High Court has passed an interim order directing the revenue that no final assessment order shall be passed without the leave of the court. The ld AR submitted that during the pendency of the writ petitions, section

Parvinder Kaur Sawhney, Gurgaon vs. Pr, CIT, Delhi -12, New Delhi

In the result, assessee’s appeals in ITA No

ITA 626/DEL/2021[2011-12]Status: DisposedITAT Delhi06 Jan 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Rajan Vohra, CAFor Respondent: Shri Nikhil Kumar Govila, CIT-DR
Section 133(6)Section 147Section 153Section 234ASection 234B

read as under: “1. erred in assessing the income of Appellant at INR 2,42,65,46,501 as against Nil returned income. Final assessment order passed is time-barred 2. erred in not passing the final assessment order within the time limit prescribed under section ... which is the outer time limit for passing the final assessment order and hence, the final assessment order dated 06.01.2025 is time barred and liable to be quashed; Order issued under section 147 read with 144C(13) of the Act following the DRP directions dated 06.01.2025 is void and invalid

Dy. Commissioner of Income Tax (International Taxation) – 3(1)(1), Mumbai vs. Jefferies Singapore Limited, Singapore

In the result, both the appeals of the Revenue are dismissed

ITA 3043/MUM/2024[2018-19]Status: HeardITAT Mumbai02 Jan 2025AY 2018-19

Bench: The Tribunal Has Been Capped At Rs.60,00,000/-. Admittedly Here In This Case The Tax Effect Is Less Than Rs.60,00,000/- & Accordingly, The Appeals Of The Revenue Are Dismissed In Limine On Account Of Low Tax Effect.

Section 143(3)

appeals have been filed by the Revenue for the quantum of assessment passed u/s.143(3) / 144C for the A.Y.2016-17 and 2018-19 against final assessment order dated 31/01/2020 and 20/03/2024 respectively. 2. At the outset, it has been pointed out that the dispute raised in the Revenue’s appeal

Novateur Electrical and Digital Systems Private Limited, Mumbai vs. ACIT - 10(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 2767/MUM/2019[2011-12]Status: DisposedITAT Mumbai31 Dec 2024AY 2011-12

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawalassessment Year: 2011-12

For Appellant: Shri Rajan Vora and Nikhil Tiwari, CAFor Respondent: Shri Pankaj Kumar, CIT DR
Section 143(3)Section 144C(3)Section 153Section 32Section 43(1)

Electrical and Digital Systems Pvt. Ltd., AY 2011-12 2. Grounds taken by the assessee are reproduced as under: Ground 1- Validity of final assessment order 1. The appellant submits that the order dated 12 May 2015 purported to be passed under section 143(3) read with section 144C ... circumstances of the case and in law, the learned CIT(A) erred in the following respects 2. in upholding the validity of the final assessment order dated 12 May 2015 passed under section 143(3) read with section 144C(3) of the Act beyond the period of limitation

Loveen Babu Vuppala, Secunderabad vs. ITO., Ward-9(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 1121/HYD/2024[2021-22]Status: DisposedITAT Hyderabad30 Dec 2024AY 2021-22

Bench: Shri Manjunatha G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1121/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2021-22) Loveen Babu Vuppala Vs. Income Tax Officer Secunderabad Ward-9(1) [Pan : Alppv1796E] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Ms.Aluru V Sai Sudha, Ar रधजस् व द्वधरध/Revenue By:: Shri R.Kumaran, Dr सुिवधई की तधरीख/Date Of Hearing: 19/12/2024 घोर्णध की तधरीख/Date Of 30/12/2024 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.08.2024 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], Kolkata, Pertaining To A.Y.2021-22 On The Following Grounds : 1. The Cit(A) Erred In Not Condoning The Delay & Not Admitting The Appeal 2. The Cit(A) Erred In Holding That There Was No Sufficient Cause For Condoning The Delay In Filing The Appeal

For Appellant: Ms.Aluru V Sai Sudha, ARFor Respondent: : Shri R.Kumaran, DR
Section 119(2)(b)Section 139(1)Section 143(1)Section 154Section 234A

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

Uber India Systems Private Limited (As Successor to Uber India Research and Development Private Limited), Hyderabad vs. DCIT., Circle-8(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 581/HYD/2022[2018-19]Status: DisposedITAT Hyderabad30 Dec 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Jehangir D MistriFor Respondent: : Ms. M.Narmada, CIT-DR
Section 144B(1)Section 144C(13)Section 92D

Uber India Systems Private Limited (As successor to Uber India Research and Development Pvt. Ltd.), (“the assessee”), feeling aggrieved by the final assessment order passed by the Learned Assessing Officer (“Ld. AO”), dated 24.08.2022 for the A.Y. 2018-19. 2. The assessee has raised the following grounds : ITA No.581/Hyd/2022 ... Appellant's total income based on the provisions of Chapter X of the Income- tax Act, 1961 ('the Act'). Final Assessment Order barred by limitation 2. On the facts and circumstances of the case and in law, the Final Assessment Order issued / passed by the learned NFAC

Zuari Cement Limited, Kadapa vs. DCIT Circle -1, Nellore

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

ITA 502/HYD/2022[2018-19]Status: DisposedITAT Hyderabad30 Dec 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Deepak Chopra, Advocate and Shri Nitin Narang,C.AFor Respondent: : Shri Kumar Pranav, CIT-DR
Section 144C(5)Section 92D

credit amounting to INR 15,33,21,507 while determining the net tax liability of the Appellant, at the time of passing the final assessment order. 40. The AO has erred by not granting the partial credit for Tax Collected at Source ("TCS") while determining the net tax liability ... Appellant, at the time of passing the final assessment order, while there is no discussion about these in the order of the AO. 41. Based on the facts and circumstances of the case and in law, the AO has erred in proposing to initiate penalty proceedings under Section 270A

Tata Chemicals Limited, Mumbai vs. PCIT-2, Mumbai

In the result, the appeal of the assessee is allowed

ITA 4/MUM/2024[2017-18]Status: DisposedITAT Mumbai30 Dec 2024AY 2017-18

Bench: Shri Amarjit Singh & Shri Anikesh Banerjeeassessment Year: 2017-18 Tata Chemicals Limited Pcit-2, Mumbai

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Pushkaraj Bhangepatil, Sr. DR
Section 143(3)Section 144C(5)Section 26(3)Section 263Section 36(1)(iii)

filed on 29.08.2017. The case was 3 Tata Chemicals Limited A.Y. 2017-18 subject to scrutiny assessment and final assessment order u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Act was passed on 28.01.2022 assessing the total income at Rs. 824,20,33,550/- under normal provisions

Eapen George, Bengaluru vs. Income Tax Officer, Ward International Taxation 1(1), Bengaluru

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

ITA 2126/BANG/2024[2019-20]Status: DisposedITAT Bangalore27 Dec 2024AY 2019-20

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Suresh Muthukrishna, CAFor Respondent: Ms. Nandini Das, CIT(DR)(ITAT), Bengaluru
Section 139Section 142Section 144Section 144CSection 147Section 148Section 234Section 69

assessee were rejected. Accordingly, the objections filed by the assessee was dismissed. 7. Consequent to that, the learned assessing officer passed the final assessment order on 22/10/2024 determining the total income of the assessee at Rs.14,637,018. 8. Aggrieved with that, the assessee is in appeal before ... opportunity of verifying those additional evidence. Therefore, IT(IT)A No.2126/Bang/2024 Page 10 of 11 the draft assessment order was confirmed. Consequently, the final assessment order was also passed. 12. In nutshell, the assessee did not get any effective opportunity of hearing before the learned assessing officer during passing

Chiara Nath, Delhi vs. DCIT - Circle Int .Tax 2(2)(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 1924/DEL/2024[2015-16]Status: DisposedITAT Delhi27 Dec 2024AY 2015-16

Bench: Shri Vimal Kumar & Shri Avdhesh Kumar Mishrachiara Nath Vs. Dcit 7, Maulseri House, Circle – Int. Tax 2(2)(2), Kapashera Estate New Delhi Delhi – 110 037 Pan : Aafpn 8540 H (Appellant) (Respondent) Assessee By Shri M. R. Sahu, C.A. & Shri Akhil Mangla, C.A. Respondent By Shri Vijay B. Vasanta, Cit-D.R. Date Of Hearing 26.11.2024 Date Of Pronouncement 27.12.2024 O R D E R Per Vimal Kumar, Jm:

Section 142(1)Section 144CSection 144C(13)Section 147Section 148Section 148ASection 149(1)

Hearing 26.11.2024 Date of Pronouncement 27.12.2024 O R D E R PER VIMAL KUMAR, JM: 1. The appeal filed by assessee challenging the final Assessment order under section 147 read with section 144C(13) of the Income Tax Act, 1961 [hereinafter referred to as “the Act”] dated ... Assessee preferred objections before DRP which were decided by order dated 19.02.2024. In compliance of direction of DRP, New Delhi, learned AO passed final assessment order dated 09.03.2024. 3. Being aggrieved appellant/assessee preferred present appeal. Vide applications dated 28.06.2024 and 09.10.2024, assessee took additional legal ground

Harley-Davidson Motor Company Inc., United States of America vs. Assistant Commissioner of Income Tax, International Tax Circle- 2(1)(1), New Delhi

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

ITA 3753/DEL/2023[2021-22]Status: DisposedITAT Delhi27 Dec 2024AY 2021-22

Bench: Shri Vimal Kumar & Shri Avdhesh Kumar Mishraharley – Davidson Motor Vs. Acit, International Tax Company Inc. Circle –2(1)(1), C/O. H-D Motor Company New Delhi India Pvt. Ltd. Building No.5, Tower A, Level-18, Dlf Cyber City Gurgaon, Haryana – 122 002 Pan : Aacch 6849 M (Appellant) (Respondent) Assessee By Shri K. M. Gupta, Adv. & Shri Jaskaran Sarkaria, C.A. Respondent By Shri Vijay B. Vasanta, Cit-D.R. Date Of Hearing 26.11.2024 Date Of Pronouncement 27.12.2024 O R D E R Per Vimal Kumar, Jm:

Section 115A(1)(b)Section 142(1)Section 143(2)Section 143(3)Section 144CSection 144C(13)Section 144C(2)(b)Section 144C(5)

Hearing 26.11.2024 Date of Pronouncement 27.12.2024 O R D E R PER VIMAL KUMAR, JM: 1. The appeal filed by assessee challenging the final Assessment order under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 [hereinafter referred to as “the Act”] dated

Sumo Logic, Inc., Usa vs. The Assistant Commissioner of Income Tax, International Taxation, Circle 3(1)(2), Delhi

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

ITA 3350/DEL/2023[2021-22]Status: DisposedITAT Delhi27 Dec 2024AY 2021-22

Bench: Shri Saktijit Dey & Shri S. Rifaur Rahman(Assessment Year : 2021-22 Sumo Logic, Inc. Vs. Acit, Circle Int. Tax 3(1)(2), 3Rd Floor, 305 Main Street, Delhi. Redwood City, California, Foreign, United States. C/O Deloitte Haskins & Sells Llp, Tower-B, 7Th Floor, Building 10, Dlf Cyber City Complex, Phase-Ii, Gurgaon-122002. (Pan: Abecs 9368 P) (Appellant) (Respondent) Assessee By : Shri Sachit Jolly, Adv. & Shri Aditya Rathore, Adv. Revenue By : Shri Vijay B Vasanta, Cit Dr Date Of Hearing : 03.10.2024 Date Of Order : 27.12.2024 O R D E R Per S. Rifaur Rahman, Am : 1. The Captioned Appeal Preferred By The Assessee Is Directed Against The Assessment Order Dated 28.09.2023 Passed By The Learned Assistant Commissioner

For Appellant: Shri Sachit Jolly, Adv. &For Respondent: Shri Vijay B Vasanta, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)

Dispute Resolution Panel-2 (“DRP” in short), New Delhi. The learned DRP has dismissed the grounds of objections raised by the assessee. Accordingly, final assessment order was passed dated 28.09.2023. Aggrieved with the above order assessee is in appeal before us. 9. At the time of hearing learned AR brought ... notice findings of the Assessing Officer in final assessment order and submitted that the assessee has developed software generated data at machine language and its recurring services offered to the clients in India on monthly and quarterly basis. Further, he brought to our notice observations of the Assessing Officer that

Best Realtrech India P.Ltd, New Delhi vs. ITO, Ward-4(3), New Delhi

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

ITA 390/DEL/2020[2011-12]Status: DisposedITAT Delhi27 Dec 2024AY 2011-12

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahmanm/S Best Realtrech Income Tax Officer, (India) Pvt. Ltd., Ward-4(3), New Delhi H-8, First Floor, Vs. Best Plaza, Netaji Subhash Place, Pitampura, Delhi-110034 Pan:Aadcb1848D (Appellant) (Respondent)

Section 132Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 153CSection 68

Thus, on fulfilment of the second condition, the bar to reopening of proceedings after expiry of four years from the date of final assessment order, under the proviso, does not apply and the initiation pf proceedings is not barred by limitation.” Ld. Sr. DR in view of the above stated

Decathlon Sports India Private Limited, Bangalore, Karnataka vs. Deputy Commissioner of Income-Tax Circle 2(2)(1), Bengaluru, Karnataka

In the result appeal of the assessee is partly allowed as indicated

ITA 1874/BANG/2024[2020-2021]Status: DisposedITAT Bangalore26 Dec 2024AY 2020-2021

Bench: Shri Prashant Maharishi

For Appellant: Shri Chavali Narayan, CA
Section 143(3)Section 92C

Appellant in relation to the store closure expenses incurred by the Appellant during the assessment proceedings The Ld. AO /DRP, passed the final assessment order which is bad and erroneous in as much as the same is without considering the decision of various Courts and Tribunals which have allowed ... payment of Rs. 33,24,39,508 were confirmed. iii. Interest on delayed receivable of Rs. 16,04,745 was confirmed. Accordingly, the final assessment order was passed on 29.7.2024 wherein the above transfer pricing adjustment as well as the corporate tax adjustment of disallowance of stored close expenses

Biocon Biologics Limited, Bangalore vs. The Assistant Commissioner of Income Tax, Circle 2(1)(1), Bangalore

ITA 1590/BANG/2024[2020-21]Status: DisposedITAT Bangalore23 Dec 2024AY 2020-21

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadavit(Tp)A No.1590/Bang/2024

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 143(3)Section 92Section 92C

assessee is aggrieved with the same and has preferred the following grounds of appeal:- “General Grounds 1. The impugned final assessment order has been passed without following due procedure laid crown in law, and hence, bad in law. 2. The impugned orders passed by the Learned AO/ Learned Transfer Pricing ... learned AO 5. The Ld. AO have erred on the facts, in circumstances of the case and in law in not passing the final assessment order within the time limit as provided under Section 153 of the Act i.e., the outer limit for passing of the final assessment order

M/S. Toyota Kirloskar Motor Pvt Ltd, Bengaluru vs. Assistant Commissioner of Income Tax, Ltu, Circle-1, Bengaluru

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

ITA 1333/BANG/2024[2011-12]Status: DisposedITAT Bangalore20 Dec 2024AY 2011-12

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2011-12 M/S. Toyota Kirloskar Motor Pvt. Ltd. Plot No.1, Bidadi Industrial Area So Bidadi Acit Vs. Ramanagar Ltu, Circle-1 Bengaluru 562 109 Banalore Pan No : Aaact5415B Appellant Respondent Appellant By : Sri Padam Chand Kincha, A.R. Respondent By : Smt. Kumutha D., D.R. Date Of Hearing : 24.09.2024 Date Of Pronouncement : 20.12.2024

For Appellant: Sri Padam Chand Kincha, A.RFor Respondent: Smt. Kumutha D., D.R
Section 143(1)Section 143(3)Section 147Section 148Section 234BSection 234B(3)Section 250

information/details including financial statement, Form 3CD, etc. Further enquiry was made by AO vide Notice dated 8.12.2014. The Appellant filed requisite information/details. The final assessment order for the impugned AY was passed on 11.01.2016. Thereafter within 10 days of passing the assessment order, the AO issued Notice under section ... review the assessment order. The AO has not demonstrated what new tangible material came before the AO within 10 days of passing the final assessment order. Reliance is place on the decision of SC in Kelvinator of India Ltd 187 Taxman 312. • The AO has relied on the assessment

Pankaj Chandrakant Pimple, Borivali (West), Mumbai vs. Int Tax Ward 3(3)(1), Mumbai

ITA 1577/MUM/2024[2017-18]Status: DisposedITAT Mumbai20 Dec 2024AY 2017-18

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am

Section 143(2)Section 144Section 144C(1)Section 148Section 148ASection 151Section 56Section 56(2)Section 69

assessee thereby directing the ld. AO to uphold the addition proposed in the draft assessment order. The ld. AO then passed the final assessment order dated 24.02.2024, u/s. 144 r.w.s. 147 r.w.s 144C(13) of the Act, being the best judgment assessment on the ground that the assessee has failed