← All Phrases

“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

Avr Storage Tank Terminals Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 11(1), Kolkata

In the result, the appeal is allowed for statistical purposes

ITA 1350/KOL/2024[2020-2021]Status: DisposedITAT Kolkata06 Dec 2024AY 2020-2021

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2020-21

For Appellant: Shri Dipran Mukherjee, ARFor Respondent: Shri P.P. Barman, Addl. CIT, Sr. DR
Section 115BSection 139(1)Section 143(3)Section 144BSection 234ASection 234BSection 234CSection 244ASection 250Section 32

assessment proceedings vide letter dated 16 September 2022 may be considered before passing the AVR Storage Tank Terminals Private Limited; A.Y. 2020-21 final assessment order. However, the Ld. AO passed the assessment order without considering the claims made by the assessee. Further, the Ld. AO erred in dealing with

Surrendra Kumar Goenka, Howrah vs. ADIT, CPC, Bengaluru / I.T.O., Ward 61(3), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1831/KOL/2024[2020-2021]Status: DisposedITAT Kolkata05 Dec 2024AY 2020-2021

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 139Section 139(1)Section 143(1)Section 234ASection 5Section 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 wade only to the extent of disallowing of FTC clam made by the petitioner

Concur Technologies (India) Private Limited, Bengaluru vs. Assistant Commissioner F Income Tax Circle 2(2)(1), Bengaluru

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

ITA 1925/BANG/2024[2020-2021]Status: DisposedITAT Bangalore05 Dec 2024AY 2020-2021

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Chavali Narayan, CAFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144C(5)Section 92B

144C(5) of the Act dated 3.6.2024. IT(TP)A No.1925/Bang/2024 Page 6 of 10 7. Based on the above direction, the final assessment order u/s. 143(3) r.w.s. 144C(13) r.w.s. 144B of the Act was passed on 3.8.2024 determining total income of assessee at Rs.37

Zydus Hospira Oncology Private Limited, Ahmedabad vs. The Pr. CIT-3, Ahmedabad

ITA 949/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad04 Dec 2024AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Prathvi Raj Meena, CIT. D.RFor Respondent: Shri Prathvi Raj Meena, CIT. D.R
Section 10ASection 10BSection 143(3)Section 263

revising the assessment order. 8. The fourth argument taken by the assessee during the course of 263 proceedings was that the final Assessment Order dated April 22, 2021, passed under Section 143(3) read with Section 144C(13) and Section 144B, which specifically mentioned the sequence of events leading

Zydus Hospira Oncology Private Limited, Ahmedabad vs. The Pr. CIT-3, Ahmedabad

ITA 948/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad04 Dec 2024AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Prathvi Raj Meena, CIT. D.RFor Respondent: Shri Prathvi Raj Meena, CIT. D.R
Section 10ASection 10BSection 143(3)Section 263

revising the assessment order. 8. The fourth argument taken by the assessee during the course of 263 proceedings was that the final Assessment Order dated April 22, 2021, passed under Section 143(3) read with Section 144C(13) and Section 144B, which specifically mentioned the sequence of events leading

Iljin Automotive Private Limited, Kanchipuram vs. DCIT Corporate Circle 2(2), Chennai

The appeal stand partly allowed in terms of our above order

ITA 1834/CHNY/2017[2013-14]Status: DisposedITAT Chennai03 Dec 2024AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1834/Chny/2017 (िनधा)रणवष) / Assessment Year: 2013-14) M/S. Iljin Automotive Private Limited Dcit बनाम/ Plot No.B1 & B2, Sipcot Industrial Park Corporate Circle-2(2), Irungattukottai, Sriperumbudur Chennai. Vs. Kanchipuram-602 105. "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aaaci-2641-E (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Sandeep Bagmar (Advocate) - Ld. Ar " थ"कीओरसे/Respondent By : Shri A. Sasikumar (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 19-11-2024 घोषणाकीतारीख /Date Of Pronouncement : 03-12-2024 आदेश / O R D E R

For Appellant: Shri Sandeep Bagmar (Advocate) - Ld. ARFor Respondent: Shri A. Sasikumar (CIT) - Ld. DR
Section 143(3)Section 144C(5)Section 32Section 43ASection 92CSection 92C(3)

order dated 03-11-2023. Accordingly, the appeal has come up for fresh hearing before the bench. This appeal arises out of final assessment order dated 18-05-2017 passed by Ld. Assessing Officer (AO) u/s 143(3) r.w.s.144C(13) of the Act pursuant to the directions of Ld. Dispute ... which was subjected to assessee’s objections before Ld. DRP. Pursuant to the directions of Ld. DR, Ld.AO passed final assessment order dated 18-05-2017 which is in further appeal before us. 1.2 The grounds raised by the assessee read as under:- The grounds of appeal stated hereunder

Debanjan Chatterjee, Kolkata vs. D.D.I.T., CPC, Bengaluru, Bengalore

In the result, the appeal of the assessee is allowed

ITA 1959/KOL/2024[2021-2022]Status: DisposedITAT Kolkata02 Dec 2024AY 2021-2022

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 1959/Kol/2024 Assessment Year: 2021-2022 Debanjan Chatterjee,……..…………….…………Appellant C-3/14, East Enclave Cooperative Society, Rajarhat, Kolkata-700156 [Pan:Aezpc7707H] -Vs.- Deputy Director Of Income Tax,………………Respondent Cpc, Bengluru, Bangalore-560500 Appearances By: Shri Nilesh Kariya, A.R., Appeared On Behalf Of The Assessee Shri Sanjay Paul, Addl. Cit,Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: November 28, 2024 Date Of Pronouncing The Order: December 02, 2024 O R D E R

Section 139Section 139(4)Section 143(1)Section 154Section 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 ... 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

Anand Nvh Products P.Ltd, New Delhi vs. DCIT, New Delhi

The appeal of the assessee is allowed with consequences to follow as per determination of the grounds as above

ITA 705/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Dec 2024AY 2017-18

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singhassessment Year: 2017-18 Anand Nvh Products P. Ltd., Vs Dcit, F-3/5, Vasant Vihar, Circle-1(1), New Delhi – 110 057. New Delhi. Pan: Aaeca0297J

For Appellant: Shri Mukesh BhutaniFor Respondent: Shri Dharamvir Singh, CIT-DR
Section 143(3)

Date of Hearing : 17.10.2024 Date of Pronouncement : 02.12.2024 ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the Assessee against the final assessment order dated 21.02.2022 of the National Faceless Assessment Centre, Delhi (hereinafter referred to as the Ld. AO) passed u/s 143(3) r.w.s

Abbas Ali Akhil, Usa vs. ACIT-Int-Tax-1, Hyderabad

In the result, the appeal of assessee in ITA No

ITA 93/HYD/2024[2018-19]Status: DisposedITAT Hyderabad29 Nov 2024AY 2018-19

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Shri K. Meghnath Chowhan, CIT-DR
Section 144CSection 144C(15)Section 144C(5)Section 147Section 148Section 15Section 153(2)Section 2(14)Section 45

month of April 2021. Therefore, the assessment should have been completed on or before 31-03-2023, whereas the AO has passed the final assessment order on 08-01- 2024, which is barred by limitation. The assessee, by an inadvertent error, could not take legal ground challenging the validity ... final assessment order passed by the AO, and thus, Hon'ble Supreme Court's decision in the case of National Thermal Power Co., Ltd., Vs. Commissioner of Income Tax, reported in (1998) 229 ITR 38 and requested for admission of additional grounds. 5. The CIT-DR, Shri Meghnath Chowhan

Abbas Ali Akhil, Usa vs. ACIT-Int-Tax-1, Hyderabad

In the result, the appeal of assessee in ITA No

ITA 92/HYD/2024[2016-17]Status: DisposedITAT Hyderabad29 Nov 2024AY 2016-17

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Shri K. Meghnath Chowhan, CIT-DR
Section 144CSection 144C(15)Section 144C(5)Section 147Section 148Section 15Section 153(2)Section 2(14)Section 45

month of April 2021. Therefore, the assessment should have been completed on or before 31-03-2023, whereas the AO has passed the final assessment order on 08-01- 2024, which is barred by limitation. The assessee, by an inadvertent error, could not take legal ground challenging the validity ... final assessment order passed by the AO, and thus, Hon'ble Supreme Court's decision in the case of National Thermal Power Co., Ltd., Vs. Commissioner of Income Tax, reported in (1998) 229 ITR 38 and requested for admission of additional grounds. 5. The CIT-DR, Shri Meghnath Chowhan

Mir Ibrahim Ali, Usa vs. ACIT, Int-Tax-1, Hyderabad

In the result, the appeal of assessee in ITA No

ITA 91/HYD/2024[2018-19]Status: DisposedITAT Hyderabad29 Nov 2024AY 2018-19

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Shri K. Meghnath Chowhan, CIT-DR
Section 144CSection 144C(15)Section 144C(5)Section 147Section 148Section 15Section 153(2)Section 2(14)Section 45

month of April 2021. Therefore, the assessment should have been completed on or before 31-03-2023, whereas the AO has passed the final assessment order on 08-01- 2024, which is barred by limitation. The assessee, by an inadvertent error, could not take legal ground challenging the validity ... final assessment order passed by the AO, and thus, Hon'ble Supreme Court's decision in the case of National Thermal Power Co., Ltd., Vs. Commissioner of Income Tax, reported in (1998) 229 ITR 38 and requested for admission of additional grounds. 5. The CIT-DR, Shri Meghnath Chowhan

Mir Ibrahim Ali, Usa vs. ACIT, Int-Tax-1, Hyderabad

In the result, the appeal of assessee in ITA No

ITA 69/HYD/2024[2016-17]Status: DisposedITAT Hyderabad29 Nov 2024AY 2016-17

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Shri K. Meghnath Chowhan, CIT-DR
Section 144CSection 144C(15)Section 144C(5)Section 147Section 148Section 15Section 153(2)Section 2(14)Section 45

month of April 2021. Therefore, the assessment should have been completed on or before 31-03-2023, whereas the AO has passed the final assessment order on 08-01- 2024, which is barred by limitation. The assessee, by an inadvertent error, could not take legal ground challenging the validity ... final assessment order passed by the AO, and thus, Hon'ble Supreme Court's decision in the case of National Thermal Power Co., Ltd., Vs. Commissioner of Income Tax, reported in (1998) 229 ITR 38 and requested for admission of additional grounds. 5. The CIT-DR, Shri Meghnath Chowhan

Simoco Systems and Infrastructure Solutions Limited, Kolkata vs. ITO Ward 2 (1), Kolkata

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

ITA 123/KOL/2024[2018-19]Status: DisposedITAT Kolkata29 Nov 2024AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Year: 2018-19

For Appellant: Indranil Banerjee, ARFor Respondent: Ankur Goyal, JCIT, Sr. DR
Section 115JSection 133(6)Section 143(3)Section 144BSection 250

show cause notice, the Ld. AO had proposed to add notional interest income by invoking section 69A the Act, however in the final assessment order he chose not to mention any section under which the addition was made. In response to this show cause notice, the assessee submitted sample copies ... March 2018 and shown in the balance sheet as short-term loans and advance under the broad head ‘current assets’. In the final assessment order, the Ld Assessing Officer reduced the outstanding balances of the parties from the above said aggregate amount of Rs 98,92,18,103/- for whom

Hasmukh Dipchand Gardi, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle-5(2), Mumbai

ITA 1309/MUM/2024[2015-16]Status: DisposedITAT Mumbai29 Nov 2024AY 2015-16

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Smt. Aarti Vissanji, ARFor Respondent: Sri Biswanath Das, CIT(DR)
Section 132Section 144CSection 153ASection 35A

passing Draft Assessment order u/s 144C 1. The Commissioner of Income Tax (Appeal) ("Ld. CIT (A)") has erred in not quashing the final assessment order passed by the Assessing Officer ("AO") without passing the draft assessment order as required u/s 144C of the Act as the appellant ... assessment order without issuing a draft assessment order. It is stated that the Ld. CIT (A) has erred in not quashing the final assessment order passed by the Assessing Officer without passing the draft assessment order as required u/s 144C of the Act as the appellant is a non-resident

Hasmukh Dipchand Gardi, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 5(2), Mumbai

ITA 1308/MUM/2024[2016-17]Status: DisposedITAT Mumbai29 Nov 2024AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Smt. Aarti Vissanji, ARFor Respondent: Sri Biswanath Das, CIT(DR)
Section 132Section 144CSection 153ASection 35A

passing Draft Assessment order u/s 144C 1. The Commissioner of Income Tax (Appeal) ("Ld. CIT (A)) has erred in not quashing the final assessment order passed by the Assessing Officer ("AO") without passing the draft assessment order as required u/s 144C of the Act as the appellant ... assessment order without issuing a draft assessment order. It is stated that the Ld. CIT (A) has erred in not quashing the final assessment order passed by the Assessing Officer without passing the draft assessment order as required u/s 144C of the Act as the appellant is a non-resident

Hasmukh Dipchand Gardi, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 5(2), Mumbai

ITA 1307/MUM/2024[2018-19]Status: DisposedITAT Mumbai29 Nov 2024AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Smt. Aarti Vissanji, ARFor Respondent: Sri Biswanath Das, CIT(DR)
Section 132Section 144CSection 153ASection 35A

passing Draft Assessment order u/s 144C 1. The Commissioner of Income Tax (Appeal) ("Ld. CIT (A)") has erred in not quashing the final assessment order passed by the Assessing Officer ("AO") without passing the draft assessment order as required u/s 144C of the Act as the appellant ... assessment order without issuing a draft assessment order. It is stated that the Ld. CIT (A) has erred in not quashing the final assessment order passed by the Assessing Officer without passing the draft assessment order as required u/s 144C of the Act as the appellant is a non-resident

Hasmukh Dipchand Gardi, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 5(2), Mumbai

ITA 1306/MUM/2024[2014-15]Status: DisposedITAT Mumbai29 Nov 2024AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Smt. Aarti Vissanji, ARFor Respondent: Sri Biswanath Das, CIT(DR)
Section 132Section 144CSection 153ASection 35A

passing Draft Assessment order u/s 144C 1. The Commissioner of Income Tax (Appeal) ("Ld. CIT(A)") has erred in not quashing the final assessment order passed by the Assessing Officer ("AO") without passing the draft assessment order as required u/s 144C of the Act as the appellant ... assessment order without issuing a draft assessment order. It is stated that the Ld. CIT (A) has erred in not quashing the final assessment order passed by the Assessing Officer without passing the draft assessment order as required u/s 144C of the Act as the appellant is a non-resident

F.C.C. Co. Ltd., Manesar, Gurgaon, Haryana vs. Assistant Commissioner of Income Tax (International Tax), Office of the Assistant Commissioner of Income Tax, D Block, Civic Center, New Delhi

ITA 819/DEL/2024[2018-19]Status: DisposedITAT Delhi29 Nov 2024AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandrafcc Co. Ltd. Vs. Acit (It), Circle (1)(3)(1) Plot No. 5, Sector 3, D Block, Civic Centre, Imt Manesar, Gurgaon, New Delhi Haryana 122001 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcf5381M Appellant .. Respondent

For Appellant: Ms. Shruti Khimta, ARFor Respondent: Ms. Surbhi Sharma, CIT, DR
Section 143(3)Section 144C(13)Section 147Section 153

ACIT(IT), Circle 1(3)(1) “3. On the facts and circumstances of the case and in law, the final assessment order u/s 143(3) read with section 144C(13) of the Income Tax Act, 1961 is barred by limitation and therefore, is void-ab-initio ... liable to be quashed as the final assessment order is in violation of the statutory provisions of section 153 of the Act. 4. On the facts and in the circumstances of the case & in law, the Ld. AO/DRP has erred in alleging the existence of a Permanent Establishment

Lnrs Data Services Limited, United Kingdom vs. Assistant Commissioner of Income Tax, Circle Int. Tax 2(2)(1), Civic Centre

In the result, both appeals of the assessee are allowed

ITA 2618/DEL/2024[2017-18]Status: DisposedITAT Delhi29 Nov 2024AY 2017-18

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 143(3)Section 144Section 144C(13)Section 148Section 234ASection 234BSection 271(1)(C)

taken in AY 2016-17: “Ground No. 1:That on the facts and in the circumstances of the case and in law, the final assessment order passed by the Learned Assessing Officer ('Ld. AO'), pursuant to the directions of the Honorable Dispute Resolution Panel ('Hon'ble Panel') is based upon ... Order so framed, the appellant/assessee approached the Dispute Resolution Panel which confirmed the proposed assessment as framed by the AO. Pursuant thereto, a Final Assessment Order was on 26 March 2024. In the Final Assessment Order, the AO has taxed the subscription fee of INR 248,077,042 by holding

Lnrs Data Services Limited, United Kingdom vs. Assistant Commissioner of Income Tax Circle Int. Tax 2(2)(1), Civic Centre

In the result, both appeals of the assessee are allowed

ITA 2617/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Nov 2024AY 2016-17

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 143(3)Section 144Section 144C(13)Section 148Section 234ASection 234BSection 271(1)(C)

taken in AY 2016-17: “Ground No. 1:That on the facts and in the circumstances of the case and in law, the final assessment order passed by the Learned Assessing Officer ('Ld. AO'), pursuant to the directions of the Honorable Dispute Resolution Panel ('Hon'ble Panel') is based upon ... Order so framed, the appellant/assessee approached the Dispute Resolution Panel which confirmed the proposed assessment as framed by the AO. Pursuant thereto, a Final Assessment Order was on 26 March 2024. In the Final Assessment Order, the AO has taxed the subscription fee of INR 248,077,042 by holding