BIRLA CARBON INDIA PRIVATE LIMITED,MUMBAI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, MUMBAI - 5, MUMBAI

In the result, the appeal is allowed as indicated above

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyabirla Carbon India Private Limited The Principal Commissioner Of Ground Floor, Aditya Birla Centre, Income Tax Room No. 515, 5Th Floor, Aaykar S. K. Ahire Marg, Worli, Vs. Mumbai-400 030 Bhavan, M. K. Road, Mumbai-400 020 Pan/Gir No. Aascs 9916 L (Appellant) : (Respondent) Appellant By : Shri Madhur Agarwal Respondent By : Shri Satyaprakash R. Singh Date Of Hearing : 16.09.2025 Date Of Pronouncement : 22.09.2025 O R D E R Per Saktijit Dey: In The Present Appeal, The Assessee Has Called Into Question The Validity Of The Order Dated 25.03.2025, Passed U/S. 263 Of The Income Tax Act, 1961 (‘The Act’ For Short) By Learned Principal Commissioner Of Income Tax (‘Ld.Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2018-19. 2. Thought Multiple Grounds Have Been Raised In The Memorandum Of Appeal, However, The Assessee Has Raised A Pertinent Preliminary Issue, Challenging The Competence & Jurisdiction Of Ld. Pcit To Invoke Powers U/S. 263 Of The Act To Revise An Assessment Order Passed U/S. 144C(13) Of The Act, In Pursuance To The Directions Of Learned Dispute Resolution Panel (Ld. Drp).

147 of the Act even empowers ld. DRP to enhance the valuation on issues which the assessee may or may not have raised. Once ld. DRP issues a direction for the guidance of the A.O. to pass the final assessment order, in terms with sub-section 13 of section 144C, the A.O. has to pass the final assessment order

ACCENTURE SOLUTIONS PRIVATE LIMITED,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, MUMBAI

In the result, the appeal is allowed as indicated above

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am Accenture Solutions Private Limited Pr. Cit, 501, 5Th Floor, Plat 3, Godrej & Boycee Compound, Vikhroli (W), Vikhroli S.O., Vs. Aayakar Bhavan, M. K. Road, Mumbai-400 079 Mumbai-400 020 Pan/Gir No. (Appellant) : (Respondent) Appellant By : Shri Nishant Thakkar Respondent By : Shri Satya Pal Kumar Date Of Hearing : 18.08.2025 Date Of Pronouncement : 28.08.2025 O R D E R Per Saktijit Dey, Vp: The Captioned Appeal Has Been Filed By The Assessee, Assailing The Order Dated 20.03.2025, Passed U/S. 263 Of Income Tax Act, 1961 (‘The Act’ For Short) By Learned Principal Commissioner Of Income Tax, Mumbai-6 (‘Ld. Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2017-18. 2. We Have Heard The Parties & Perused The Materials Available On Record. The Short Issue Arising For Consideration Is Whether The Final Assessment Order Passed U/S. 144C(13) Of The Act, Can Be Subjected To Revisionary Jurisdiction U/S. 263 Of The Act. For Deciding This Issue, Few Necessary Facts Are Required To Be Considered. The Assessee Is A Resident Corporate Entity Engaged In The Business Of Providing Information Technology (It)/Information Technology Enabled Service (Ites) To Its Group Companies As Well As Consulting Services To Its Clients. For The Assessment Year Under Dispute, The Assessee Filed

147 of the Act even empowers ld. DRP to enhance the valuation on issues which the assessee may or may not have raised. Once ld. DRP issues a direction for the guidance of the A.O. to pass the final assessment order, in terms with sub-section 13 of section 144C, the A.O. has to pass the final assessment order

ATOS INDIA PRIVATE LTD,MUMBAI vs. ACIT 14 (1) (1) , MUMBAI

In the result, the appeal filed by the assessee stands allowed on the additional grounds

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleatos India Private Limited V. Acit – 14(1)(1) Unit No. 1401, 14Th Floor Rom No. 481, 4Th Floor Supremus “E" Wing Aayakar Bhavan M.K. Road, Mumbai - 400020 I Think Techno Campus Kanjurmarg (E), Mumbai - 400042 Pan: Aaaco2461J (Appellant) (Respondent) Assessee Represented By : Ms. Chandni Shah & Ms. Riddi Maru Department Represented By : Shri Vachaspati Tripathi

147 Page No. 2 Atos India Private Limited (book value of INR 20,76,06,565 reduced by voluntary adjustment with respect to Non-AE segment INR 6,26,28,418), and while doing so:  ignoring that the Appellant had supported its claims with appropriate evidences;  challenging the commercial rationale and expediency in availing the services from the AEs;  ignoring

ICICI BANK LTD.,MUMBAI vs. THE DY CIT -2(3)(1), MUMBAI

In the result we hold that the learned principal

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Icici Bank Limited The Dy. Commissioner Of Icici Bank Towers, Income-Tax-2(3)(1), Aayakar Bhavan, 5 Th Floor, Bandra Kurla Complex, Vs. Bandra (East), Room No.552, Mumbai-400 051 M.K.Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaaci1195H Appellant By : Ms Arati Vissanji, Ar Respondent By : Shri Nikhil Chaudhary, Cit Dr Date Of Hearing: 13.01.2022 Date Of Pronouncement : 08.03.2022

144C of the Act and hence the period of limitation as given in section 263(2) of the Act ought to be reckoned from the date of the original assessment order and not the reassessment order. This has been held by the Bombay High Court in the Bank's own merged entity case lClCl Limited vide order

SHAPOORJI PALLONJI AND COMPANY PRIVATE LIMITED ,MUMBAI vs. PRINCIPLE COMMISSIONER OF INCOME TAX (CENTRAL),-4, MUMBAI

In the result, the appeal of the assessee is allowed

5,00,000 while computing book profits under Section 115JB Act 3.1. Subsequently, the case was selected for scrutiny assessment under section 143(2) of the Act vide notice dated 08/08/2013. During the assessment proceedings, the ld. AO issued notices u/s 143(2) and 142(1) of the Act dated 17/11/2014. In the said notice the ld. AO had asked

THE INDIAN HOTELS CO. LTD.,MUMBAI vs. PR. CIT-1, MUMBAI

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Amarjit Singh, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.950/Mum/2021 (ननधधारण वर्ा / Assessment Years: 2014-15) बनधम/ The Indian Hotels Company Pcit-1 Room No.330, 3Rd Floor, Ltd. Vs. 9Th Floor, Express Towers, Aayakar Bhavan, Barrister Rajini Patel Marg, Maharishi Karve Road, Nariman Point, Mumbai- Mumbai-400020. 400021. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaact3957G (अपीलाथी /Appellant) (प्रत्यथी / Respondent) .. Assessee By: Shri K. K. Ved Revenue By: Shri Surendra Kumar (Dr) सुनवाई की तारीख / Date Of Hearing: 17/03/2022 घोषणा की तारीख /Date Of Pronouncement: 12/04/2022 आदेश / O R D E R Per Amarjit Singh, Jm: The Assessee Has Filed The Present Appeal Against The Order Dated 31.03.2021 Passed By The Principal Commissioner Of Income Tax-01, Mumbai [Hereinafter Referred To As The “Pcit”] Relevant To The A.Y.2014-15 In Which The Principal Commissioner Of Income Tax-01 Has Invoked The Revisional Power U/S 263 Of The I.T. Act, 1961. 2. The Assessee Has Raised The Following Grounds Of Appeal: - “Re.: Validity Of Order U/S, 263; On The Facts & In The Circumstances Of The Case & In Law, The Impugned Order Dated 31 March 2021 Passed Under Section 263 Of The Act Is Without Jurisdiction & Bad In Law. Without Prejudice To The Above, On The Facts & Circumstances Of The Case & In Law, The Principal Commissioner Of Income Tax (“Pcit”) Has Erred In Passing The Order Dated 31 March 2021 U/S. 263 Of The Act.

147 TT] 649) (Kol) - In this case, the assessee advanced secured loans as interest free funds to subsidiary, which was used by it for purpose of business i.e. hospitality business / construction of hotels. The interest on secured loan was denied by AO. The Tribunal, while relying on S. A. Builders Ltd (supra), held that once commercial expediency is established, interest

THE HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED -INDIA BRANCHES ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

144C(3) was made on 03.02.2017. Since, 4\nyears form the end of the relevant year has expired in this case, the requirement\nto initiate proceeding u/s 147 are reason to believe that income for the year\nunder consideration has escaped assessment because of failure on the part of\nthe assessee to disclose fully and truly all material facts necessary

INTELENET GLOBAL SERVICES PRIVATE LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX 12(2), MUMBAI

The appeal of the assessee is partly allowed in terms of our aforesaid observations

Bench: Shri M. Balaganesh () & Shri Ravish Sood () M/S Intelenet Global Services Pvt. Acit – 12(2), 145, Aaykar Ltd; Intelenet Towers, Plot Cst No. Vs. Bhawan, Maharshi Karve Marg, 1406-A/28, Mindspace, Malad (W), Mumbai – 400 020 Mumbai – 400 090. Pan No. Aaaci7387P (Assessee) (Revenue) Assessee By : Shri S.K Tyagi, A.R Revenue By : Shri V. Sreekar, Cit D.R Date Of Hearing : 24/02/2021 Date Of Pronouncement : 24/05/2021

reassessment order under section 143(3) r.w.s. 147 of the Act, for the AY 2009-10, he had allowed ground No. 4 of the appellant regarding addition of Rs.32,21,48,679/-, under section 68 of the Act, the same could not be added by the AO in the computation of income, in the impugned order under section

HSBC SECURITIES AND CAPITAL MARKETS (INDIA) PRIVATE LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, MUMBAI-4, MUMBAI

In the result, the appeal filed by the Assessee stands allowed

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawalassessment Year: 2014-15

reassessment order, which is not subject matter before us . 4. The Ld. PCIT considering the order dated 30.03.2022 passed by the Faceless Assessing Officer (in short “FAO”) found that FAO has ignored the assessed income of Rs.52,35,41,450/-. Further, an amount of Rs.1,68,03,023/- was disallowed in view of the provision of section

DCIT(IT)-2(2)(2), NARIMAN POINT vs. THE HONGKONG AND SHANGHAI BANKING CORPORATION LTD, BANDRA

144C(3) was made on 03.02.2017. Since, 4\nyears form the end of the relevant year has expired in this case, the requirement\nto initiate proceeding u/s 147 are reason to believe that income for the year\nunder consideration has escaped assessment because of failure on the part of\nthe assessee to disclose fully and truly all material facts necessary

DCIT(CC)-8(3) , MUMBAI vs. SHAPOORJI PALLONJI AND COMPANY PRIVATE LIMITED, MUMBAI

In the result, the cross-objection of the assessee is partly\nallowed, whereas the appeal of the Revenue is dismissed

5, the assessee has challenged the\nvalidity of the reassessment proceedings on the ground that the\nreopening was based on borrowed satisfaction, contending that the\nAssessing Officer merely acted upon information received from\nanother source without independent application of mind.\n7.1 The learned counsel for the assessee submitted that the\nformation of “reason to believe” under section 147

INCOME TAX OFFICER (IT)-3(2)(1), KAUTILYA BHAWAN vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Amit Shukla & Shri Girish Agrawal

5. 16th February Notice u/s 142(1) of the Act 29-30 2022 6. 1st March 2022 Objection filed with respect to 31-43 reopening for reassessment 9 ITA Nos. 3674/Mum/2025 and ors. Shapoorji Pallonji Mistry AYs 2015-16 and 2016-17 7. 25th May 2022 Notice u/s 148A(b) along with statements 44-79 and 20th June of Sanjay

M/S WF ASIAN SMALLER COMPANIES FUND LIMITED,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE 4(3)(2), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.459/Mum/2023 (निर्धारण वर्ा / Assessment Years: 2013-14) M/S. Wf Asian Smaller बिधम/ Acit, Circle-4(3)(2) Companies Fund Ltd Room No. 1611, 16Th Vs. C/O Ankul Goyal, Azb & Floor, Air India Building, Partners A8, Sector-4, Nariman Point, Mumbai- Noida 201301. 400021. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaacw5648R (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Deepak Chopra/Ankul Goyal Revenue By: Shri Soumedu Kumar Dash (Sr. Dr) सुनवाई की तारीख / Date Of Hearing: 28/03/2023 घोषणा की तारीख /Date Of Pronouncement: 23/06/2023 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Passed By The Ao Dated 19.01.2023 U/S 147 R.W.S 144C(13) Of The Income Tax Act, 1961 (Hereinafter “The Act”) Pursuant To The Direction Issued By The Ld. Dispute Resolution Panel (Drp) For Ay. 2013-14. 2. The Assessee Has Raised The Legal Issue Challenging The Action Of The Ao To Have Reopened The Original-Scrutiny-Assessment U/S 143(3) Of The Act, After Four (4) Years [From The End Of The Relevant Assessment Year] Without Satisfying The Additional Condition Precedent As Prescribed In The Proviso To Section 147(1) Of The Act. Since The Assessee Has Raised The Legal Issue Assailing The Jurisdiction Of Ao To Have Issued Notice U/S 148 Of The Act, Proposing Re-Opening Of The Original Assessment [Framed Under Scrutiny Under Section 143(3) Of The Act], We Will Adjudicate It First. For Appreciating The Legal Issue, Let Us

144C(13) of the Income Tax Act, 1961 (hereinafter “the Act”) pursuant to the direction issued by the Ld. Dispute Resolution Panel (DRP) for AY. 2013-14. 2. The assessee has raised the legal issue challenging the action of the AO to have reopened the original-scrutiny-assessment u/s 143(3) of the Act, after four (4) years [from

ULTRA TECH CEMENT LIMITED,MUMBAI vs. ACIT- CC 1(4), MUMBAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon’Bledeputy Commissioner Of Income Tax V. M/S. Ultratech Cement Ltd., Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan, Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Jt. Commissioner Of Income Tax (Osd) V. M/S. Ultratech Cement Ltd. Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan Andheri (E), Mumbai- 400093 Old C.G.O. Bldg, (Annexe) M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) & M/S. Ultratech Cement Limited V. Dcit, Central Circle- 1(4) [Acit, Cc] Room. No 902, 9Th Floor Ahura Centre, B-Wing, 2Nd Floor Pratishtha Bhavan Mahakali Caves Road Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 Maharishi Karve Road Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

section 143(3) r.w.s. 147 of the Income-tax Act, 1961 (IT Act). 2. On the facts and in the circumstances of the case and in law, the learned LD CIT(A) erred in confirming that the reassessment was validly carried out by DCIT, despite the following: Four years had elapsed from the end of relevant - assessment year and having

JT. CIT (ODS) - CC -1(4), MUMBAI vs. ULTRATECH CEMENT LTD., MUMBAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon’Bledeputy Commissioner Of Income Tax V. M/S. Ultratech Cement Ltd., Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan, Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Jt. Commissioner Of Income Tax (Osd) V. M/S. Ultratech Cement Ltd. Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan Andheri (E), Mumbai- 400093 Old C.G.O. Bldg, (Annexe) M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) & M/S. Ultratech Cement Limited V. Dcit, Central Circle- 1(4) [Acit, Cc] Room. No 902, 9Th Floor Ahura Centre, B-Wing, 2Nd Floor Pratishtha Bhavan Mahakali Caves Road Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 Maharishi Karve Road Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

section 143(3) r.w.s. 147 of the Income-tax Act, 1961 (IT Act). 2. On the facts and in the circumstances of the case and in law, the learned LD CIT(A) erred in confirming that the reassessment was validly carried out by DCIT, despite the following: Four years had elapsed from the end of relevant - assessment year and having

M/S. ULTRATECH CEMENT LTD,MUMBAI vs. DCIT CENT CIR-1(4) , MUMBAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon’Bledeputy Commissioner Of Income Tax V. M/S. Ultratech Cement Ltd., Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan, Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Jt. Commissioner Of Income Tax (Osd) V. M/S. Ultratech Cement Ltd. Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan Andheri (E), Mumbai- 400093 Old C.G.O. Bldg, (Annexe) M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) & M/S. Ultratech Cement Limited V. Dcit, Central Circle- 1(4) [Acit, Cc] Room. No 902, 9Th Floor Ahura Centre, B-Wing, 2Nd Floor Pratishtha Bhavan Mahakali Caves Road Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 Maharishi Karve Road Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

section 143(3) r.w.s. 147 of the Income-tax Act, 1961 (IT Act). 2. On the facts and in the circumstances of the case and in law, the learned LD CIT(A) erred in confirming that the reassessment was validly carried out by DCIT, despite the following: Four years had elapsed from the end of relevant - assessment year and having

DCIT CIR 1(4) , MUMBAI vs. M/S. ULTRATECH CEMENT LTD, MUMBAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon’Bledeputy Commissioner Of Income Tax V. M/S. Ultratech Cement Ltd., Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan, Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Jt. Commissioner Of Income Tax (Osd) V. M/S. Ultratech Cement Ltd. Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan Andheri (E), Mumbai- 400093 Old C.G.O. Bldg, (Annexe) M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) & M/S. Ultratech Cement Limited V. Dcit, Central Circle- 1(4) [Acit, Cc] Room. No 902, 9Th Floor Ahura Centre, B-Wing, 2Nd Floor Pratishtha Bhavan Mahakali Caves Road Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 Maharishi Karve Road Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

section 143(3) r.w.s. 147 of the Income-tax Act, 1961 (IT Act). 2. On the facts and in the circumstances of the case and in law, the learned LD CIT(A) erred in confirming that the reassessment was validly carried out by DCIT, despite the following: Four years had elapsed from the end of relevant - assessment year and having

ALBERT JOSEPH ROZARIO,MUMBAI vs. ITO, INT. TAX, CIRCLE 4(1)(1), MUMBAI, MUMBAI

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

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Albert Joseph Rozario, Ito, (Int. Tax), Circle-4(1)(1), B-311, 5Th Wing, Room No. 629, 6Th Floor, Inlaks Park, Vs. Kautilya Bhavan, Yari Road, Versova, C-41 To C-43, G Block, Andheri West, Bandra Kurla Complex, Mumbai-400058 Bandra East, Pan : Afvpr6139P Mumbai-400051 (Appellant) (Respondent) For Assessee : Shri Dharan Gandhi For Revenue : Shri Sridhar G. Menon, Sr.Dr Date Of Hearing : 01-05-2025 Date Of Pronouncement : 22-07-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Final Assessment Order Passed By The Assessing Officer U/S 147 R/W 144C(13) Of The Act Dt. 30-12-2024, Consequent To The Directions Given By The Ld. Drp-1, Mumbai-3, U/S 144C(5) Of The Act, Dated 30-11-2024 Pertaining To Assessment Year (Ay.) 2018-19. 2. Briefly The Facts Of The Case Are That Basis Information Available Through The Insight Portal That The Assessee Had Purchased Immoveable Properties Amounting To Rs. 8,31,45,549/- & Has Received Interest

section 56(2)(x) of the Act, the assessee‟s objections were disposed off as not maintainable and addition made by the AO was held to be good in law. 6. Following the aforesaid directions of the DRP, the AO passed the final assessment order u/s. 147 r.w.s. 144C(13) of the Act, vide order dt. 30-12- 2024; wherein