“reassessment proceedings”

ReassessmentSections 147-151Sections 147-1518,150 judgments

The decision most relied on for reassessment proceedings is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on reassessment proceedings

CIT v. Kelvinator of India Ltd.

320 ITR 561 · 2010 · Supreme Court

1,673

citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

GKN Driveshafts (India) Ltd. v. ITO

259 ITR 19 · 2003 · Supreme Court

1,349

citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.

291 ITR 500 · 2007 · Supreme Court

1,030

citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

Raymond Woollen Mills Ltd. v. ITO

236 ITR 34 · 1999 · Supreme Court

862

citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

ITO v. Lakhmani Mewal Das

103 ITR 437 · 1976 · Supreme Court

721

citing judgments

For reassessment proceedings, the 'reason to believe' that income has escaped assessment must be based on some material and not mere suspicion, establishing a live link between the information and the belief. Furthermore, for reassessment beyond four years, there must be a specific finding of the assessee's failure to disclose fully and truly all material facts.

Hindustan Lever Ltd. v. R.B. Wadkar

268 ITR 332 · 2004 · High Court

695

citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

PCIT v. Meenakshi Overseas Pvt. Ltd.

395 ITR 677 · 2017 · High Court

471

citing judgments

Reassessment proceedings initiated solely based on an investigation wing/appraisal report, without the Assessing Officer's independent application of mind to form a 'reason to believe' that income has escaped assessment, are beyond jurisdiction, bad in law, and void ab initio.

Ranbaxy Laboratories Ltd. v. CIT

336 ITR 136 · 2011 · High Court

398

citing judgments

In reassessment proceedings under Section 147/148, the Assessing Officer can assess other income not specified in the original notice if the initial ground for reopening assessment is found to be valid. However, if the income for which the assessment was initially reopened is found not to have escaped assessment, the Assessing Officer cannot proceed to assess any other income.

Judgments citing reassessment proceedings

Vikas Sharma, New Delhi vs. DCIT Circle 55(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 290/DEL/2024[2015-16]Status: DisposedITAT Delhi28 Aug 2024AY 2015-16

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Sumit Lalchandani, Adv. &For Respondent: Ms. Monika Dhami, CIT-DR

Section 115BSection 144BSection 147Section 148Section 148ASection 151ASection 234ASection 250(6)Section 69A

referred to as 'CIT(A)') vide order dated 28.11.2023 has also erred in upholding the said assessment order. 2. That the initiation of the reassessment proceedings for A.Y. 2015- 16 is illegal, bad in law, without jurisdiction, time-barred, and liable to be quashed. 3. That the assessment order dated ... same have not been issued in accordance with the provisions of Section 151A of the Act and as such, the consequential reassessment proceedings are illegal and deserves to be set aside. 7. That in view of the facts and circumstances of the case and in law, the notice dated

Preet International Pvt Ltd, New Delhi vs. ACIT Circle-20(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 3600/DEL/2019[2010-11]Status: DisposedITAT Delhi28 Aug 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Vimal Kumarpreet International Pvt. Ltd, Vs. Acit, 240, Ff, Dda Office Complex Circle-20(1), Cycle Market, Jhandewalan New Delhi Extn, New Delhi (Appellant) (Respondent) Pan: Aaaco9321J Assessee By : Shri Ved Jain, Adv Ms. Supriya Mehta, Ca Revenue By: Shri Vivek Vardha, Sr. Dr Date Of Hearing 05/06/2024 Date Of Pronouncement 28/08/2024

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Vivek Vardha, Sr. DR

Section 143(3)Section 147Section 148

casethe Ld. CIT(A) has erred both on facts and in law in rejecting the contention of the assessee that the initiation of the reassessment proceedings and the reassessment order are bad both on facts and in law and liable to be quashed as the statutory conditions and procedure prescribed ... with 4. On the facts and circumstances of the case, learned [CIT(A)] has erred in rejecting the contention of the assessee that the reassessment proceedings initiated by the learned A.O. are bad in the eye of law as the reasons recorded for the issue of notice under Section

DCIT, Circle, Patiala vs. M/S Punjab State Power Corporation Ltd., Patiala

In the result, ground no. 1 & 3 of the Revenue’s appeal is allowed and ground no

ITA 737/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh27 Aug 2024AY 2017-18

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Rajiv Saldi, CAFor Respondent: Smt. Kusum Bansal, CIT, DR

Section 143(2)

submitted that the issue of treatment of business income vs. income from other sources has already been decided by the AO in reassessment proceedings in favour of the assessee company for A.Y. 2011-12 and subsequent year upto A.Y. 2014-15 and also by the AO in assessment proceedings ... into account, the Ld. CIT(A) returned the finding stating that the issue under consideration has already been decided by the AO in the reassessment proceedings in favour of the assessee company in earlier years and subsequent year and since issue stands covered in favour of the assesee company

Hirenkumar Lavjibhai Kanani, Ahmedabad vs. PCIT, Ahmedabad

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

ITA 522/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad27 Aug 2024AY 2015-16

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

For Appellant: Shri Sagar Shah, A.RFor Respondent: Shri H. Phani Raju, CIT DR

Section 144BSection 147Section 2(22)(e)Section 263

declaring total income of Rs. 4,79,940/-. The return was Hirenkumar Lavjibhai Kanani vs. PCIT Asst.Year –2015-16 - 2– subsequently subject to reassessment proceedings under section 147 of the Act, which were initiated based on the information that the assessee had received unsecured loans/advances from M/s. Yash EPC Projects ... where the assessee held a significant shareholding. 3. The reassessment proceedings were initiated for the limited scrutiny purpose of verifying the applicability of the provisions of Section 2(22)(e) of the Act, which deals with "Deemed Dividend". The Assessing Officer (AO), after considering the submissions and explanations provided

Gayatri Creatives, Ahmedabad vs. The ACIT, Circle-2(2) Now Circle 2(1)(1), Ahmedabad

In the result, appeal of the assessee is allowed

ITA 565/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad27 Aug 2024AY 2010-11

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2010-11

Section 139Section 142Section 143Section 143(2)Section 143(3)Section 147Section 148

case wherein the assessee has categorically mentioned that the assessee has objected the reopening of the assessment under Section 148 during the reassessment proceedings thereby stating that the assessee has followed work-in- progress method of accounting and already paid taxes accordingly. The CIT(A) has totally ignored this fact ... reasons to that effect. Hence, on merit also the assessee proves that the disallowance made by the Assessing Officer is not justified in reassessment proceedings. Thus, on merit also the assessee succeeds. 10. In the result, appeal of the assessee is allowed. Order pronounced in the open Court on this

M/S. Victor Commercial Co. Ltd., Kolkata vs. ACIT, CC - 1(2), Kolkata

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 1127/KOL/2024[2010-2011]Status: DisposedITAT Kolkata27 Aug 2024AY 2010-2011

Bench: Shri Rajpal Yadav & Shri Rakesh Mishraassessment Year: 2009-10 & Assessment Year: 2010-11 M/S Victor Commercial Co. Acit, Central Circle-1(2), Ltd., Kolkata, C/O. M/S Salarpuria Jajodia & Aayakar Bhawan Poorva, Vs Co., 7, C.R., Avenue, 3Rd Floor, 110, Shantipally, E.M. Kolkata - 700072 Bypass, Kolkata - 700017 (Pan: Aabcv0011C) (Appellant) (Respondent)

For Appellant: S. Jhajaria, ARFor Respondent: Pradip Biswas, Addl. CIT

Section 147Section 148Section 250

appellant had filed the return under protest in response to such notice u/s 148. Subsequently, scrutiny proceedings were taken up and the reassessment proceedings were completed vide order u/s 147/143(3) wherein certain adjustment/additions/disallowances were made and the income was assessed at Rs.20,35,380/- as against the returned income

Padam Kumar Goyal, Tonk vs. ITO Ward-Tonk, Income Tax Department, Tonk

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

ITA 581/JPR/2024[2012-13]Status: DisposedITAT Jaipur27 Aug 2024AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Nikhilesh Kataria (C.A)For Respondent: Smt. Monisha Choudhary (Addl. CIT)

Section 131Section 143(2)Section 144Section 147Section 148

recorded by the Id. AO were factually incorrect and proceedings were initiated without any application of mind and accordingly notice u/s 148 and consequent reassessment proceedings have become bad in law and Id. CIT(A) erred in sustaining the same and hence, the reassessment proceeding is prayed to be quashed ... absence of "reason to believe" and incorrect facts recorded by the AO while issuing notice u/s 148 and change in stand in reassessment proceedings. The appellant has stated that in the reasons recorded, the appellant is stated to be doing business of purchases from farmers and sales to wholesellers

Goyal Vegoils Limited, Kasar, Kota vs. DCIT, Circle -2, Kota

In the result ground no. 2 & 3 raised by the assessee

ITA 243/JPR/2024[2012-13]Status: DisposedITAT Jaipur27 Aug 2024AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Rajendra Sisodia, CAFor Respondent: Sh. Anoop Singh, Addl. CIT

Section 143(3)Section 147Section 148Section 250

Assessing Officer on account of obtaining accommodation entry and commission paid thereupon, when the reopening was based on identical facts as during the earlier reassessment proceedings and thus amounted to change of opinion which is not a valid ground for reopening of assessment, as held by the Supreme Court ... prejudice to the above, it would be pertinent to mention that the issue relating to accommodation entries was already examined at the time of reassessment proceedings on earlier occasion. Issuing a notice for re-assessment on the same issue, amounts to change of opinion by the AO. The assessee relies

Jet Infraventure Limited, Mumbai vs. ITO Ward-12(3)(1), Mumbai

In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for stati...

ITA 2337/MUM/2024[2013-14]Status: DisposedITAT Mumbai27 Aug 2024AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Appellant: Ms. Rajeshwari Menon, Sr. DRFor Respondent: Mr. Gunjan H Kakkad

Section 133(6)Section 147Section 148Section 68

being accommodation to believe that said unsecured loan being accommodation entry and hence income escaped assessment. income escaped assessment. 3.1 During the course of reassessment proceedings, the Assessing During the course of reassessment proceedings, the Assessing During the course of reassessment proceedings, the Assessing Officer asked the assessee to justify ... Before us, the Ld. counsel for the assessee did not counsel for the assessee did not press the grounds challenging the validity of the reassessment proceedings and therefore, the ground validity of the reassessment proceedings and therefore, the ground validity of the reassessment proceedings and therefore, the ground

Jayantilal Patel (Legal Heir of Late Gopalbhai Arjan Patel), Pune vs. ITO- 30(1)(4), Mumbai

ITA 2051/MUM/2024[2011-12]Status: DisposedITAT Mumbai27 Aug 2024AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2011-12 Late Sh Gopalbhai Arjan Patel Through Ito-30(1)(4), Legal Heir Sh Jayantilal Gopalbhai Patel Pratyashakar Bhavan, C- Flat No. 301-401, Patel Wood Products, Vs. 13, Bandra Kurla Shivkrupa Buildign, Sr. No. 58 4 2, Complex, Bandra East, Gangadham Katraj Road, Kondhwa, Mumbai-400051. Pune-411048. Pan No. Aadpp 9057 F (Deceased) Appellant Respondent

For Appellant: Mr. Abhilash HirenFor Respondent: 11/07/2024

Section 148Section 250Section 253(1)(a)

proceedings challenging raised by the appellant during the appellate proceedings challenging raised by the appellant during the appellate proceedings challenging the validity of the reassessment proceedings and notices being not the validity of the reassessment proceedings and notices being not the validity of the reassessment proceedings and notices being ... February 2024. Grounds Grounds Grounds challenging challenging challenging the the the validity validity validity of of of the the the reassessment reassessment reassessment proceedings: d) The learned Assessing Officer erred in law'and facts and The learned Assessing Officer erred in law'and facts and The learned Assessing Officer erred

ACIT, Circle-24(1), Mumbai vs. Jasvinder Kalyan Saluja, Mumbai

In the result, the cross the result, the cross-objections of the assessee are allowed of the assessee are allowed whereas appeal of the Revenue is dismissed

ITA 1987/MUM/2024[2013-14]Status: DisposedITAT Mumbai27 Aug 2024AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2013-14 Acit, Circle-24(1), Jasvinder Kalyan Saluja, 601, 6Th Floor, K-1, Balkrishna Chs, Jp Piramal Chambers, Lalbaug, Vs. Road, Andheri West, Parel, Mumbai-400053. Mumbai-400012. Pan No. Amgps 5143 Q Appellant Respondent

For Appellant: Mr. Ajay SinghFor Respondent: 08/07/2024

Section 69A

assessee challenged validity of the On further appeal, the assessee challenged validity of the On further appeal, the assessee challenged validity of the reassessment proceedings as well as addition on merit. The Ld. reassessment proceedings as well as addition on merit. The Ld. reassessment proceedings as well as addition ... assessment order). the Balance Sheet (as admitted by the AO in the assessment order). iii) It is evident that the AO initiated reassessment proceeding on the iii) It is evident that the AO initiated reassessment proceeding on the iii) It is evident that the AO initiated reassessment proceeding

Shrikant Finconsery Private Limited, Mumbai vs. PCIT-4, Mumbai

In the result, all three appeals preferred by the Appellant are allowed

ITA 1558/MUM/2024[2013-14]Status: DisposedITAT Mumbai27 Aug 2024AY 2013-14

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri J.P.BairagraFor Respondent: Shri Kishor Dhule

Section 133(6)Section 143(2)Section 144BSection 147Section 263

under Section 143(3) of the Act was passed on 25/08/2015 by the Assessing Officer, accepting the return income as assessed income. 6.1. Subsequently, reassessment proceedings were initiated on the basis of information received from the Deputy Director of Income Tax (Investigation), Unit 7(4), Mumbai, vide letter dated 30/09/2016 ... during the relevant Assessment year 2013-14. However, ignoring the objections, the Assessing Officer Assessment Year: 2013-14 to 2015-16 continued with the reassessment proceedings. In response to the notice, dated 03/06/2021, issued under section 143(3) read with Section 147 of the Act, the Appellant filed reply, dated

Shrikant Finconserv Private Limited, Mumbai vs. PCIT-4, Mumbai

In the result, all three appeals preferred by the Appellant are allowed

ITA 1557/MUM/2024[2014-15]Status: DisposedITAT Mumbai27 Aug 2024AY 2014-15

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri J.P.BairagraFor Respondent: Shri Kishor Dhule

Section 133(6)Section 143(2)Section 144BSection 147Section 263

Jet Infraventure Limited, Mumbai vs. ITO Ward-12(3)(1), Mumbai

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

ITA 1020/MUM/2024[2013-14]Status: DisposedITAT Mumbai27 Aug 2024AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Appellant: Mr. Gunjan H KakkadFor Respondent: Ms. Rajeshwari Menon, Sr. DR

Section 133(6)Section 147Section 148Section 68

Assessing Officer recorded reason to believe that said unsecured loan being accommodation entry and hence income escaped assessment. 3.1 During the course of reassessment proceedings, the Assessing Officer asked the assessee to justify the genuineness of the loan of Rs.80,00,000/- shown in the bank accounts of the assessee ... running from pages 1 to 106. Before us, the Ld. counsel for the assessee did not press the grounds challenging the validity of the reassessment proceedings and therefore, the ground Nos. 2 and 8 and other grounds wherever validity has been challenged, are dismissed as infructuous

Late Sharmishta Mafatlal Mehta, Mumbai vs. Commissionr of Income Tax (A), NFAC, Delhi, Mumbai

ITA 4219/MUM/2023[2010-11]Status: DisposedITAT Mumbai27 Aug 2024AY 2010-11

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Hemant MehtaFor Respondent: Shri Avinash Baburao Karpe

Section 133(6)Section 142(1)Section 143(3)Section 254Section 27(3)

sides and perused material on record. 5. It is admitted position that this is the second round of litigation. 6. In the first round, reassessment proceedings were initiated against the Assessee on the basis of information received from the Director General Income Tax, (Investigation), Mumbai to the effect that ... Assessee had accommodation entries for bogus purchase bills. The aforesaid reassessment proceedings culminate into order, dated 26/03/2014, passed under Section 143(3) read with Section 147 of the Act, whereby addition of INR.1,67,41,917/- was made in the hands of the Assessee under Section

Kissan Fats Ltd., Bathinda vs. DCIT, CC-1, Ludhiana

In the result, the appeal of the assessee is allowed

ITA 408/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh26 Aug 2024AY 2013-14

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR

Section 133(6)Section 143(3)Section 147Section 148Section 151(1)Section 250(6)Section 253

speaking order’ dt. 24/01/2022 the Ld. AO disposed off the objections of the assessee. Page 95 of Paper Book. 9. That thereafter the reassessment proceedings commenced with replies filed by the assessee during the course of reassessment proceedings, however the replies and documents filed by the assessee were not considered ... purchases and thus further addition of Rs. 1,22,790/- was made on account of alleged commission paid. 10. During the course of the reassessment proceedings, the assessee had sought statement of Hitesh Jain basis which the completed assessment was reopened by the Department but the said statement

Salarpuria Properties Pvt. Ltd., Kolkata vs. DCIT, CC - 3(2), Kolkata

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

ITA 988/KOL/2024[2006-2007]Status: DisposedITAT Kolkata26 Aug 2024AY 2006-2007

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Section 147

Shri P. Dayanand Pai. From the reasons to believe, it is evident that the documents relied upon for the purpose of initiating the reassessment proceedings are seized documents which have been seized in the course of search from a third person, unrelated to the assessee. Page 4 of 7 I.T.A

Purple Suppliers Pvt. Ltd., Surat, Gujrat vs. A.C.I.T., Circle - 5(1), Kolkata

In the result, all the three appeal for AYs 2011-12 to 2013-14 of the assessee are allowed

ITA 759/KOL/2022[2013-2014]Status: DisposedITAT Kolkata26 Aug 2024AY 2013-2014

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.757 To 759/Kol/2022 Assessment Years: 2011-12 To 2013-14 Purple Suppliers Pvt. Ltd. ………. Appellant (Pan: Aafcp2218P) Vs. Asstt. Commissioner Of Income Tax, Circle-5(1), Kolkata. ………… Respondent Appearances By: Shri Anil Kochar, Advocate Appeared For Appellant. Shri Subhendu Datta, Cit, Dr Appeared For Respondent. Date Of Concluding The Hearing : 28.05.2024 Date Of Pronouncing The Order : 26.08.2024 Order Per Manish Borad: The Captioned Appeals Filed At The Instance Of The Assessee Pertaining To The Assessment Years (In Short “Ay”) 2011-12 To 2013-14 Are Directed Against The Separate Orders Passed U/S 250 Of The Income Tax Act, 1961 (In Short The “Act”) By Ld. Commissioner Of Income-Tax, Appeal, National Faceless Appeal Centre (Nfac), Delhi [In Short Ld. “Cit(A)”] Dated 03.11.2022 Arising Out Of The Separate Assessment Orders U/S 143(3)/147 Of The Act By Acit, Circle-5(1), Kolkata Dated 31.12.2018. Since Grounds Of Appeal Raised In These Appeals Are Common & Facts Are Identical, Except Variance In Amount, With The Consent Of Both The Parties, We Proceed To Dispose Of All These Appeals By This Consolidated Order For The Sake Of Brevity & Convenience.

Section 143(3)Section 147Section 148Section 250Section 69C

raises suspicious. Both the registered address and return addresses of the company are in Kolkata but directors are based in Mumbai.” 4. In the reassessment proceedings assessee submitted certain details to explain that the purchases are genuine and sales have also Page 5 of 31 I.T.A. No. 757 to 759/Kol/2022 ... complete details of purchase bills, copy of trade receivables, financial statement of the company, VAT returns. However, Ld. AO was not and he completed reassessment proceedings making the addition u/s. 69C of the Act on account of bogus purchases from SDPL for the following amount: Assessment Year Amount

Purple Suppliers Pvt. Ltd., Surat, Gujrat vs. A.C.I.T., Circle - 5(1), Kolkata

In the result, all the three appeal for AYs 2011-12 to 2013-14 of the assessee are allowed

ITA 758/KOL/2022[2012-2013]Status: DisposedITAT Kolkata26 Aug 2024AY 2012-2013

Section 143(3)Section 147Section 148Section 250Section 69C

Purple Suppliers Pvt. Ltd., Surat, Gujrat vs. A.C.I.T., Circle - 5(1), Kolkata

In the result, all the three appeal for AYs 2011-12 to 2013-14 of the assessee are allowed

ITA 757/KOL/2022[2011-2012]Status: DisposedITAT Kolkata26 Aug 2024AY 2011-2012

Section 143(3)Section 147Section 148Section 250Section 69C