This compilation indexes twelve rulings — spanning the Income Tax Appellate Tribunal (ITAT) benches at Mumbai, Chennai, and Lucknow, and the High Courts of Punjab & Haryana, Madras, Gujarat, Bombay, and Karnataka — in which Section 144C(3) of the Income-tax Act, 1961 formed a central or co-operative ground of challenge or adjudication. The cases range from June 2024 through August 2026 and predominantly involve international taxation circles, faceless assessment proceedings, and eligible assessees (including foreign companies and non-residents). The index is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a structured starting point for jurisdictional research on final assessment orders passed under Section 144C(3).

Research index only. This page is a structured case-law reference compiled from source judgments. Nothing here constitutes legal advice, tax advice, or a recommendation to take any particular course of action. Readers must independently verify each ruling against the full text of the judgment and check for subsequent stays, appeals, or reversals.

The statutory framework in one paragraph

Section 144C of the Income-tax Act, 1961 establishes a dispute-resolution mechanism applicable to "eligible assessees" (broadly, persons in whose case transfer-pricing adjustments are made, or foreign companies as notified). Sub-section (1) requires the Assessing Officer, before passing a final assessment order, to forward a draft order to the assessee and provide an opportunity to file objections before the Dispute Resolution Panel (DRP). Sub-section (2) sets the time limit within which the assessee may file such objections. Sub-section (3) provides that where the assessee does not object within the period specified under sub-section (2), or where the assessee intimates acceptance of the draft order, the Assessing Officer shall pass the final assessment order in conformity with the draft order. It is this final order passed under Section 144C(3) — typically read with Section 143(3) where scrutiny assessments are involved — that forms the subject of challenge across the twelve rulings indexed below.

The 12 rulings

1. Payal Kurz,Maharastra vs Income Tax Department, Maharstra

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 11 August 2026
Sections engaged: 144C(3), 147, 148, 148A(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee against the order of the Commissioner of Income Tax (Appeals)-57, Mumbai, arising out of reassessment proceedings initiated under Section 147 of the Act. Per the source preview, the reassessment was initiated by issuing an order and notice dated 21.12.2022 under Section 148A(d) and Section 148 of the Act, and the assessment order was subsequently passed under Section 147 read with Section 144C(3); the assessee contended that such notice, along with the consequential assessment order, was liable to be quashed in view of a concession made by the Revenue before the Supreme Court in a cited precedent.

2. ACIT International Taxation 4.3.2 vs Wexford Spectrum Investors Mauritius

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 10 August 2026
Sections engaged: 143(3), 144C(3), 147, 148, 74, 90
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1914/Mum/2026) was filed by the Revenue for Assessment Year 2015-16, with a cross-objection (C.O. No. 155/Mum/2026) filed by the assessee, Wexford Spectrum Investors Mauritius Limited (PAN: AAACW7770L). The source preview indicates this is a cross-appeal matter before the "I" Bench, Mumbai, heard on 13.05.2026 and pronounced on 10.08.2026; the substantive grounds are not fully set out in the available preview beyond the sections cited.

3. Ucweb Mobile Private Ltd vs Assessment Unit, Income Tax Department

Bench: Punjab-Haryana High Court
Date: 7 August 2026
Sections engaged: 143(2), 143(3), 144C(1), 144C(10), 144C(15)(b), 144C(2), 144C(3), 144C(5), 156, 270A, 274, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner challenged, by way of Civil Writ Petition No. 4329 of 2024 before the Punjab and Haryana High Court, the final assessment order dated 15.12.2023 pertaining to Assessment Year 2021-22, passed under Section 143(3) read with Section 144C(3) of the Income-tax Act, 1961. The writ petition was reserved on 07.07.2026 and the full judgment was pronounced on 07.08.2026; the breadth of sections cited indicates the challenge engaged multiple procedural and substantive limbs of Section 144C, including the transfer-pricing framework under Section 92C.

4. Palani Vel Rajan,Chennai vs ITO, Intl Taxn Ward 2(1), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 15 June 2026
Sections engaged: 56(2)(x), 144C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 3909/Chny/2025) was directed against the order dated 20.11.2025 of the Commissioner of Income Tax (Appeals)-16, Chennai, arising out of the assessment order dated 22.04.2025 framed under Section 147 read with Section 144C(3) of the Income-tax Act, 1961, for Assessment Year 2020-21. The assessee (PAN: AMLPP0584D) was represented before the 'B' Bench, Chennai, and the matter was heard on 25.03.2026 and pronounced on 15.06.2026.

5. Marriott International Innc ,Mumbai vs DCIT (International Taxation) 3(2)

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 8 June 2026
Sections engaged: 143(3), 144C(1), 144C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA No. 1622 & 1623/Mum/2021) covered Assessment Years 2013-14 and 2014-15, filed by Marriott International Inc. (PAN: AAECM8040K) before the "I" Bench, Mumbai. The source preview records that the matter was heard on 09.04.2026 and pronounced on 08.06.2026, and notes that in addition to the main grounds the appellant raised supplementary submissions; multiple precedents were cited on the record by the parties, though the full substantive reasoning is not reproduced in the available preview.

6. Dev Anand Bhatt,Haldwani vs Ddit/ADIT(Intl Tax) Lkn, Lucknow

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 4 June 2026
Sections engaged: 10, 143(3), 144C(3), 250, 270, 270A, 270A(2), 60, 62, 74
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 764/LKW/2025) was filed by the assessee (PAN: ANOPB1987A) against the order of the Commissioner of Income Tax (Appeals)-2, Noida, dated 30.09.2025, pertaining to Assessment Year 2019-20. Per the source preview, the principal ground raised was that the CIT(A) erred in sustaining a penalty order under Section 270A of the Act amounting to Rs. 8,47,596, the underlying addition having been made in an order under Section 143(3) read with Section 144C(3).

7. M/S.Visteon Corporation vs The Assistant Commissioner Of Income

Bench: Madras High Court
Date: 4 November 2025
Sections engaged: 144C(3), 144C(2)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner, a foreign company represented by its authorised signatory, filed Writ Petition No. 16616 of 2024 under Article 226 of the Constitution of India seeking a writ of certiorari to quash the impugned order bearing DIN ITBA/AST/S/143(3)/2024-25/1065265392(1) dated 30.05.2024, passed under Section 143(3) read with Section 144C(3) of the Income-tax Act, 1961, for Assessment Year 2022-23. Per the source preview, the petitioner is a foreign company having business in India and approached the court challenging that final assessment order.

8. M/S. American Megatrends vs Assessment Unit

Bench: Madras High Court
Date: 6 October 2025
Sections engaged: 144C(2), 144C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed Writ Petition No. 20517 of 2025 under Article 226 of the Constitution of India seeking a writ of certiorari to quash the assessment order in ITBA/AST/143(3)/2025-26/1076473876(1) dated 27.05.2025, together with the consequential notice of demand and penalty notices, all passed in conjunction with proceedings engaging Section 144C(2) and Section 144C(3) of the Act. The source preview records that challenges were also raised to associated penalty notices issued in the same round of proceedings.

9. Bwci Pension Trustees Limited vs The Commissioner Of Income Tax

Bench: Madras High Court
Date: 21 January 2025
Sections engaged: 144, 147, 144C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner, a Guernsey-based pension trustee entity represented by its Director, filed Writ Petition No. 5246 of 2024 under Article 226 of the Constitution of India seeking a writ of certiorarified mandamus to quash the impugned order dated 11.05.2023 (No. ITBA/COM/F/17/2023-24/1052749779(1)) and to direct the respondent to provide an opportunity to the petitioner to present its case before passing an assessment order under Section 144 read with Section 147 and Section 144C(3) of the Income-tax Act, 1961.

10. Shobhna Doshi vs Assistant Commissioner Of Income Tax

Bench: Gujarat High Court
Date: 30 September 2024
Sections engaged: 144C(2), 144C(3), 144C(5)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed Special Civil Application No. 13048 of 2023 (with an accompanying Civil Application for Stay No. 1 of 2024) under Article 227 of the Constitution of India before the Gujarat High Court at Ahmedabad. Per the source preview, the court noted that the controversy was in a narrow compass and, with the consent of both parties, took the matter up for hearing; the sections engaged indicate the challenge centred on the procedural requirements and timelines under Section 144C(2), Section 144C(3), and Section 144C(5) of the Act.

11. Paypal Payments Private Limited vs Assistant Commissioner Of Income Tax

Bench: Bombay High Court
Date: 13 August 2024
Sections engaged: 143(3), 144C(3), 144B
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed Writ Petition (L) No. 30944 of 2023 under Article 226 of the Constitution of India before the Bombay High Court, praying inter alia that the final assessment order dated 17.10.2023 passed under Section 143(3) read with Section 144C(3) and Section 144B of the Act be quashed and set aside, together with the notice of demand dated 17.10.2023 and associated penalty notices. The petition was reserved on 8 August 2024 and pronounced on 13 August 2024.

12. Zoomrx Healthcare Technology vs The Additional/Joint/Deputy/

Bench: Karnataka High Court
Date: 11 June 2024
Sections engaged: 144C(3), 144C(2)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed Writ Petition No. 13955 of 2024 (T-IT) under Articles 226 and 227 of the Constitution of India before the Karnataka High Court at Bengaluru, praying for a writ of certiorari to quash the impugned order dated 20.11.2023 bearing DIN ITBA/AST/S/144/2023-24/1058081333(1), passed under Section 144 read with Section 144C(3) of the Income-tax Act, 1961, for AY 2021-22. The matter involved the National Faceless Assessment Centre, Delhi and the Deputy Commissioner of Income Tax, Circle 7(1)(1), Bengaluru as respondents.

Patterns across these 12 rulings

International taxation circle prevalence. Across a significant portion of these cases, the assessing authority is an International Taxation circle or ward (e.g., International Taxation Ward 2(1) Chennai, International Taxation Circle 2(2) Madras, International Taxation Circle 3(2)(1) Mumbai, DDIT/ADIT International Tax Lucknow). This indicates that Section 144C(3) disputes are disproportionately concentrated in the international taxation segment, consistent with the provision's original design for eligible assessees such as foreign companies and transfer-pricing cases.
Writ jurisdiction extensively invoked. Multiple cases in this index — before the Madras High Court (cases 7, 8, 9), the Bombay High Court (case 11), the Gujarat High Court (case 10), the Karnataka High Court (case 12), and the Punjab and Haryana High Court (case 3) — were filed under Articles 226 and/or 227 of the Constitution of India seeking writs of certiorari (or certiorarified mandamus) against final assessment orders passed under Section 144C(3). The frequency of writ filings signals that parties regularly bypass or supplement the appellate route before ITAT and challenge the final order at the High Court stage.
Section 144C(3) routinely read with Section 143(3). In several rulings (cases 3, 5, 7, 11), the final assessment order was passed under Section 143(3) read with Section 144C(3), reflecting the procedural architecture where a scrutiny assessment concluded through the draft-order mechanism culminates in a final order citing both provisions. Researchers tracking these orders should note that a search limited to either section alone may miss relevant precedents.
Reassessment proceedings intersecting with Section 144C(3). Cases 1, 2, 4, and 9 demonstrate that Section 144C(3) final orders can arise not only in original scrutiny proceedings but also in reassessment contexts (Section 147, Section 148), including post-Faceless Assessment era proceedings. This creates layered challenges where both the validity of the reopening and the procedural correctness of the Section 144C route are simultaneously contested.
Faceless Assessment Centre as a common respondent. Cases 3, 8, and 12 name the National Faceless Assessment Centre, Delhi, as a respondent. This reflects the post-2020 faceless assessment framework's integration with the Section 144C mechanism, and practitioners researching jurisdiction and service-of-notice issues in Section 144C(3) orders should account for the faceless infrastructure when analysing these rulings.

How to use this compilation

This index is a starting point for jurisdictional and sectional research, not a substitute for reading the full text of each judgment. Every ruling listed above should be independently retrieved from the source court portal (indiankanoon.org, the Madras High Court's judis portal, or the respective ITAT order repository) and read in its entirety before being relied upon for any research purpose. The text previews reproduced here are truncated extracts only, and substantive reasoning, operative directions, and conditional orders may appear in portions of the judgment not visible in the preview.

Researchers should also check whether any of these orders have been subsequently stayed, appealed, reversed, or affirmed at a higher forum. An ITAT order may have been challenged before the relevant High Court; a High Court order may be pending before the Supreme Court. Outcome fields marked "Outcome not specified in source" mean the operative direction could not be confirmed from the available preview — the full judgment must be consulted to determine what relief, if any, was granted. Do not treat the absence of a recorded outcome as indicative of any particular result.

Finally, readers should cross-reference applicable CBDT circulars, instructions, and any Finance Act amendments that may have modified the operation of Section 144C between the assessment year under dispute and the date of the ruling. Statutory amendments, including modifications to timelines or the definition of "eligible assessee," can affect the precedential weight of older rulings when applied to more recent assessment years.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 144C(3) Final Assessment Orders: 12 ITAT and HC Rulings (2024–2026)