2026 (6) TMI 1438

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....JUDICIAL MEMBER For the Appellant : Shri Himanshu S Sinha, Adv, Shri Prashant Meharchandani, Adv Shri Jainender Singh Kataria, Adv For the Respondent : Shri S. K. Jadhav, CIT DR ORDER PER M. BALAGANESH, A. M.: 1. The Assessee Canon India Pvt Ltd (hereinafter referred to as 'assessee) by filing the present appeal sought to set aside the impugned assessment order dated 01.12.2025 pass....

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.... of Canon Group primarily engaged in the distribution of compressive range of digital products that includes photocopiers, multifunctional peripherals, fax machines, printers, scanners, digital cameras and multimedia projectors. The original return was filed by the assessee company for assessment of 2022-23 on 29.11.2022, declaring total income of Rs. 168,98,83,680/- which was later revised on 28.....

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.... account of AMP expenditure as stated supra. The assessee preferred objections before the ld Dispute Resolution Panel (DRP). The ld DRP disposed of the objections of the assessee vide its directions u/s. 144C(5) of the Act dated 08.10.2025. It is pertinent to note that DIN was generated for the purpose of DRP directions and the DRP directions u/s. 144C(5) of the Act dated 8.10.2025 was uploaded in....

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.... date for the purpose of all sections of the Act. It is not the case of the revenue that the DRP directions dated 08.10.2025 was not received by the ld AO on 8.10.2025, being the date of uploading in the ITBA portal. We find from the perusal of the final assessment order, which is duly digitally signed by the AO, the order is dated 01.12.2025 and the same is delayed by 12 minutes and 21 seconds, w....