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“draft assessment order”

Assessment ProceduresSection 144CSection 144C4,773 judgments

The decision most relied on for draft assessment order is ACIT v. Serajuddin & Co. (454 ITR 312), cited in 580 judgments on BharatTax.

Leading authorities on draft assessment order

ACIT v. Serajuddin & Co.
454 ITR 312 · 2023 · High Court
580
citing judgments

Approval under Section 153D of the Income Tax Act is mandatory for assessment orders in search cases. While elaborate reasons for approval are not required, the approving authority must provide some indication that it has examined the draft orders and found them to meet the requirements of law.

Principal Commissioner of Income-tax v. Subodh Agarwal
149 Taxmann.com 373 · 2023 · High Court
194
citing judgments

Approval of draft assessment orders under Section 153D must be granted with due application of mind, not mechanically. Approving multiple cases, such as 38 in a single day, without proper scrutiny amounts to mechanical approval, rendering the assessment invalid.

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.

JCB India Ltd. v. DCIT
398 ITR 189 · 2017 · High Court
49
citing judgments

The requirement to pass a draft assessment order under Section 144C of the Act is mandatory. A final assessment order issued without such a draft order is a nullity, constituting an incurable jurisdictional error that cannot be saved by Section 292B, even in set-aside proceedings following an ITAT remand.

Aggarwal v. NFAC
127 Taxmann.com 637 · High Court
34
citing judgments

Denying a personal hearing when specifically requested, especially after a search and during a pandemic, violates the principles of natural justice. The assessment and appellate proceedings themselves were conducted during the COVID-19 pandemic.

Hire Purchase (P.) Ltd. v. NFAC
128 Taxmann.com 190 · High Court
34
citing judgments

Failure to grant a personal hearing to an assessee when income is likely to be varied based on submitted evidence violates the principles of natural justice and renders the assessment order invalid.

Chandrakant Dharia v. ITO
469 ITR 262 · Reported
34
citing judgments

An adverse assessment order cannot be passed without granting an opportunity of personal hearing to the taxpayer. Where income is to be varied based on evidence, a personal hearing is mandatory.

Judgments citing draft assessment order

Saurabh Jayant Bhagat, Panvel Raigad vs. Income Tax Officer, ITO Panvel

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

ITA 2717/PUN/2024[2013-2014]Status: DisposedITAT Pune07 May 2025AY 2013-2014

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2717 & 2718/Pun/2024 िनधा"रण वष" / Assessment Year: 2013-14 Saurabh Jayant Bhagat, The Income Tax Officer, A-806, Balaji Aangan, Nr. S T V Panvel. Depot, Panvel Raigad–410206. S. Maharashtra. Pan: Aklpb9996P Appellant/ Assessee Respondent / Revenue Assessee By Shri Gaurang Khakhkhar – Ar(Virtual) Revenue By Shri Abhinay Kumbhar & Shri Vinod Pawar – Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 07/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, Date 31.05.2024 For The A.Y.2013-14. The Assessee Has Raised The Following Grounds Of Appeal : “1) The Honorable Commissioner Of Income Tax (A) Has Erred In Law As Well As On Facts In Upholding The Reassessment Proceedings Without Communicating The Reason For Reopening Of Assessment.

Section 250Section 250(4)Section 250(6)Section 251(1)(a)Section 69Section 69ASection 69C

erred has erred in law as well as on facts in upholding the reassessment order with the above referred addition after issuing draft assessment order wherein null addition is proposed by Ld' Assessing officer. 6) That the order passed by the Ld.CIT u/s.250 of the I.T.Act, 1961 was arbitrary

Biogenex Life Sciences Private Limited, Hyderabad vs. DCIT, Circle 1(1), Hyderabad

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 68/HYD/2022[2017-18]Status: DisposedITAT Hyderabad07 May 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: : Smt. M. Narmada, CIT-DR
Section 143(3)Section 92C

No.68/Hyd/2022 2 2. The assessee has raised the following grounds of appeal : “ 1. On the facts and circumstances of the case, the Draft Assessment Order (DAO) dated 23.03.2021 passed by the Add./Jt./Dty/Asst. CIT/ITO, National e-Assessment Centre, Delhi, (herein after referred ... vide his order dt.29.01.2021 ITA No.68/Hyd/2022 6 suggested upward adjustment of Rs.1,05,79,088/-. Accordingly, the Ld. AO passed the draft assessment order on 23.03.2021. 4. Aggrieved with the draft assessment order passed by the Ld. AO, the assessee preferred objections before the Ld. DRP. In pursuance

Sri Maharaja Refineries, Erode vs. ACIT, Circle-I, Erode

ITA 1956/CHNY/2024[2014-15]Status: DisposedITAT Chennai07 May 2025AY 2014-15

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकरअपीलसं./I.T.A.Nos.1955 & 1956/Chny/2024 (निर्धारणवर्ष / Assessment Years: 2013-14 & 2014-15) Sri Maharaja Refineries, # 128, Bhavani Road, Erode-638 004. Vs The Assistant Commissioner Of Income-Tax, Circle-1, Erode. Pan: Aaffs-8491-N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे / Appellant By प्रत्यर्थीकीओरसे/Respondent By : Mr. S.Sridhar, Advocate (Erode) : Mr. R.Clement Ramesh Kumar, Cit & Ms.Anitha, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 19.02.2025 घोषणाकीतारीख / Date Of Pronouncement : 07.05.2025 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeals Filed By The Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)(Nfac), Delhi [Cit(A)] Both Dated 07.06.2024 For

For Respondent: Mr. S.Sridhar, Advocate (Erode)
Section 143(2)Section 143(3)Section 153(5)Section 40A(2)Section 40A(2)(a)Section 40A(2)(b)Section 92

passed the order on 28/10/2016, which shows in pages- 10 to 12 the rates of Palm oil. The Assessing Officer, while passing a draft assessment order u/s.143(3) r.w.s.144C(I) dt.23/12/2016 referred the above order of the TPO. Thus, as argued in detail, the Revenue was in possession

Sri Maharaja Refineries, Erode vs. ACIT, Circle-1, Erode

ITA 1955/CHNY/2024[2013-14]Status: DisposedITAT Chennai07 May 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकरअपीलसं./I.T.A.Nos.1955 & 1956/Chny/2024 (निर्धारणवर्ष / Assessment Years: 2013-14 & 2014-15) Sri Maharaja Refineries, # 128, Bhavani Road, Erode-638 004. Vs The Assistant Commissioner Of Income-Tax, Circle-1, Erode. (प्रत्यर्थी/Respondent) Pan: Aaffs-8491-N (अपीलार्थी/Appellant) अपीलार्थीकीओरसे / Appellant By : Mr. S.Sridhar, Advocate (Erode) प्रत्यर्थीकीओरसे/Respondent By : Mr. R.Clement Ramesh Kumar, Cit & Ms.Anitha, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 19.02.2025 घोषणाकीतारीख / Date Of Pronouncement : 07.05.2025 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeals Filed By The Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)(Nfac), Delhi [Cit(A)] Both Dated 07.06.2024 For

For Appellant: Mr. S.Sridhar, Advocate (Erode)For Respondent: Mr. R.Clement Ramesh Kumar
Section 143(2)Section 143(3)Section 153(5)Section 40A(2)Section 40A(2)(a)Section 40A(2)(b)Section 92

passed the order on 28/10/2016, which shows in pages- 10 to 12 the rates of Palm oil. The Assessing Officer, while passing a draft assessment order u/s.143(3) r.w.s. 144C(I) dt.23/12/2016 referred the above order of the TPO. Thus, as argued in detail, the Revenue was in possession

Akshay Kumar Rungta, Bangalore vs. Income Tax Officer, Ward 2(1), International Taxation

In the result, appeal filed by the assessee is allowed as per above terms

ITA 66/BANG/2024[2015-16]Status: DisposedITAT Bangalore07 May 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

For Appellant: Shri. Ravishankar S. V, AdvocateFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 10(38)Section 143(3)Section 144CSection 147Section 147rSection 148Section 151Section 153Section 153CSection 250

additional grounds of appeal raised by the assessee is as under: IT(IT)A No.66/Bang/2024 Page 5 of 31 1. The draft assessment order dated 31/03/2022 passed u/s 144C of the Act is not valid in the eye of law and is non-est as it is not signed ... from time to time in response to notice placed on record and AO has considered while completing the reassessment. Accordingly, the AO prepared draft Assessment Order under section 144C of the Act vide Order dated 31.03.2022 and issued to the assessee. Since assessee is a non- resident, therefore, the case

Shri. Anantula Vijay Mohan, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-6(1)(1), Bangalore

ITA 2060/BANG/2024[2017-18]Status: DisposedITAT Bangalore07 May 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

Section 143(3)Section 250

ITA No.2059 & 2060/Bang/2024 & SP 67/Bang/2024 Anantula Vijay Mohan, Hyderabad IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH: BANGALORE BEFORE SHRI

Anantula Vijay Mohan, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-6(1)(1), Bangalore

ITA 2059/BANG/2024[2016-17]Status: DisposedITAT Bangalore07 May 2025AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

For Respondent: Sri Padma Khincha, A.R
Section 143(3)Section 250

ITA No.2059 & 2060/Bang/2024 & SP 67/Bang/2024 Anantula Vijay Mohan, Hyderabad IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH: BANGALORE BEFORE SHRI

Hipe Infrastructure Projects LLP, Bangalore vs. Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, appeal filed by the assessee is allowed

ITA 1338/BANG/2024[2018-19]Status: DisposedITAT Bangalore06 May 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year :2018-19

For Appellant: Shri. Narendra Kumar Jain, AdvocateFor Respondent: Shri. Sunil Kumar Agarwal, CIT(DR)(ITAT), Bangalore
Section 143(2)Section 68Section 69

which is not applicable to the case of the assessee. He also referred to Draft Assessment Order which is placed at Paper Book Page Nos.132 to 139 and submitted that the assessee is required maintain books of accounts as per Rule 24 of the LLP Rules, 2009. Section

Institute Management Committee Iti Jhalawar, Jhalawar vs. ITO Ward Jhalawar, Jhalawar

The appeals of the assessee are hereby allowed

ITA 41/JPR/2025[2014-15]Status: DisposedITAT Jaipur05 May 2025AY 2014-15

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Assessee In This Appeal Has Raised The Following Grounds;

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 10Section 144Section 147Section 151Section 234

exemption claimed under section 10 amounting Rs.28,50,537/- was not considered as allowable. Based on that contention Id. AO prepared the draft assessment order and sent to the assessee to show cause why the assessment should not be completed based on those observations vide show cause dated ... response to the said notices. Again, the Assessing Officer provided opportunity to the assessee to furnish reply. Thereafter, the Assessing Officer prepared draft assessment orders and sent the same to the assessee in respect of each assessment year. Show cause notices dated 11.02.2022 were also issued. However, the assessee

Institute Management Committee Iti Jhalawar, Jhalawar vs. ITO Ward Jhalawar, Jhalawar

The appeals of the assessee are hereby allowed

ITA 39/JPR/2025[2013-14]Status: DisposedITAT Jaipur05 May 2025AY 2013-14

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Assessee In This Appeal Has Raised The Following Grounds;

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 10Section 144Section 147Section 151Section 234

exemption claimed under section 10 amounting Rs.28,50,537/- was not considered as allowable. Based on that contention Id. AO prepared the draft assessment order and sent to the assessee to show cause why the assessment should not be completed based on those observations vide show cause dated ... response to the said notices. Again, the Assessing Officer provided opportunity to the assessee to furnish reply. Thereafter, the Assessing Officer prepared draft assessment orders and sent the same to the assessee in respect of each assessment year. Show cause notices dated 11.02.2022 were also issued. However, the assessee

Pralhad Vasantrao Mulick, Pune, Maharashtra vs. The ITO, (It) Ward-3, Pune, Maharashtra

In the result, appeal of the assessee is allowed

ITA 452/PUN/2025[2015-2016]Status: DisposedITAT Pune05 May 2025AY 2015-2016
Section 139(1)Section 147Section 148Section 148ASection 69

during the year. The Assessing Officer-ITO, Ward-6(5), Pune issued show cause notice u/s.148A(b) of the Act. As per the Draft Assessment Order, Assessee had not filed any reply, hence an order u/s.148A(d) of the Act was passed on 02.04.2022. Then, a notice u/s.148 was issued

Dsm Shared Services India Private Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

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

ITA 501/HYD/2022[2018-19]Status: DisposedITAT Hyderabad05 May 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Aliasgar Rampurawala, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 43B

account of ITES and Rs. 5,39,289/- on account of interest on trade receivables. Accordingly, the Ld. AO passed the draft assessment order on 10.09.2021. 5. Aggrieved with the draft assessment order passed by the Ld. AO, the assessee preferred objection before the Ld. DRP. In pursuance ... under Section 144C (5) of the Income tax Act, 1961 vide order dated 08.06.2022 on the objection filed by the assessee against the draft assessment order passed by the AO dated 10.09.2021. Subsequently, the assessee filed an application for rectification dated 11.07.2022 received in this office on 12.07.2022 and submitted

Gainsight Software Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle 2(1), Hyderabad

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

ITA 200/HYD/2021[2016-17]Status: DisposedITAT Hyderabad05 May 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Aliasgar Rampurawala, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 271ASection 37(1)Section 438

account of provision of SDS and Rs.10,57,723/- on account of interest on trade receivables. Accordingly, the Ld. AO passed the draft assessment order on 04.11.2019. 4. Aggrieved with the draft assessment order passed by the Ld. AO, the assessee preferred objection before the Ld. DRP. In pursuance

Open Text Technologies India Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad

ITA 2387/HYD/2018[2014-15]Status: DisposedITAT Hyderabad05 May 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Madhusudan Sawdia, Hon'Ble

For Appellant: Revenue byFor Respondent: Date of hearing
Section 143(3)Section 92B

Provision of Software Development Service (“SDS”) and Rs.1,65,98,428/- on account of outstanding trade receivables. Accordingly, the Ld. AO passed draft assessment order on 30.11.2017. Aggrieved with the draft assessment order passed by the Ld. AO, the assessee preferred objections before the Ld. DRP. In pursuance

Wns Global Services Private Limited, Mumbai vs. Asessment Unit, National Faceless Assessment Centre, New Delhi

In the result, the appeal of the assessee bearing ITA No

ITA 4432/MUM/2024[AY 2020-2021]Status: DisposedITAT Mumbai05 May 2025

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarwns Global Services Private Vs Assessment Unit, National Faceless Limited, Mumbai Assessment Centre, New Delhi Pl-10/11, Gate No.4, Godrej- Boyce Complex, Pirojshanagar, L.B.S.Marg, Vikhroli (West), Mumbai-400 079 Pan: Aaacw2598L Appellant Respondent

For Appellant: ShriPorus Kaka A/w Manish KanthFor Respondent: Shri Pankaj Kumar (CIT DR)
Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 253

deemed loan – Rs. 6,95,92,686/- Total Adjustment: Rs. 11,26,24,233/- Aggrieved by the proposed adjustment made in the draft assessment order issued under section 144C(1) of the Act, the assessee filed objections before the Ld. DRP under section 144C(2).The Ld.DRP, vide its directions

International Seaport Dredging Limited, Chennai vs. DCIT, Chennai

The appeal stand allowed

ITA 72/CHNY/2018[2013-14]Status: DisposedITAT Chennai02 May 2025AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकर अपील सं./ Ita No.72/Chny/2018 (िनधा)रणवष) / Assessment Year: 2013-14) & आयकर अपील सं./ It (Tp)A No.35/Chny/2018 (िनधा)रणवष) / Assessment Year: 2014-15) & आयकर अपील सं./ It (Tp)A No.87/Chny/2019 (िनधा)रणवष) / Assessment Year: 2015-16) M/S. International Seaport Dredging Dcit / Jcit(Osd) Private Limited, Corporate Circle-2(2) बनाम 5Th Floor, Challam Towers, Chennai. Old No.62, New No.113, / Vs. Dr.Radhakrishnan Salai Chennai-600 004. "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aabci-2286-E (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Ashik Shah (C.A) – Ld.Ar ""थ"कीओरसे/Respondent By : Shri A.Sasi Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 05-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 02-05-2025 आदेश / O R D E R Per Manu Kumar Giri, Jm: These Appeals By Assessee For Assessment Years (Ay) 2013-14 & 2014-15 Arise Out Of The Separate Orders Of Assessments Framed By Ld.

For Appellant: Shri Ashik Shah (C.A) – Ld.ARFor Respondent: Shri A.Sasi Kumar (CIT) -Ld. DR
Section 143(3)

Transfer Pricing Officer (‘TPO’ in short) and the Assessing Officer ('AO' in short) made certain adjustments / disallowances to the assessee's income. Against draft assessment order of the AO, the Appellant filed its objections before the Dispute Resolution Panel ('DRP' in short

Rekha Modi, Delhi vs. Joint Commissioner of Income Tax, Central Circle-1, Noida

In the result, the appeal of the assessee is allowed

ITA 4559/DEL/2024[2019-20]Status: DisposedITAT Delhi02 May 2025AY 2019-20

Bench: Sh. Shamim Yahya & Sh. Sudhir Kumarassessment Year: 2019-20 Rekha Modi Vs. Jcit Central Circle -1 E-380, First Floor, Greater Noida Kailash Part-I, New Delhi Pan No.Aaepm8105E (Appellant) (Respondent)

Section 132Section 142(1)Section 143(2)Section 143(3)Section 153BSection 153DSection 156Section 69A

discussed with AO by the Add. Commissioner of Income Tax Meerut Range which can been seen the letter dated 28-09-2021. The draft assessment orders for approval and letter of approval reproduce as under: 11 u 8. We have heard the parties and perused the material available ... Legality of approval granted u/s 153D-allegation of perusing the records for each assessment year separately - HELD THAT:- We find that only draft assessment orders were sent to JCIT without any assessment or search record. The approvals establishes that approving authority has granted the approvals, without reasons or depicting having

Sherdil Nath, New Delhi vs. ITO, Ward Int. Tax. 2(1)(2), Delhi

In the result, the captioned appeals of the Assessees are allowed

ITA 1505/DEL/2022[2017-18]Status: DisposedITAT Delhi02 May 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 153CSection 153D

pronouncements, sought for allowing the Appeal and prayed for quashing the assessment order. 4. Per contra, the Ld. Departmental Representative submitted that the draft assessment orders have been perused by the Joint Commissioner of Income Tax,Central Range Gurugram, while according approval u/s 153D of the Act on 30/12/2019 ... 20/05/2024 at 21:34:51 requires the approving authority, i.e. Joint Commissioner to verify the issues raised by the Assessing Officer in the draft assessment order and apply his mind to ascertain as to whether the required procedure has been followed by the Assessing Officer or not in framing

Atotech India Pvt. Ltd., Gurgaon vs. DCIT, Gurgaon

In the result, the appeals filed by the assessee is partly allowed

ITA 6571/DEL/2016[2012-13]Status: HeardITAT Delhi02 May 2025AY 2012-13

Bench: Shri Mahavir Singh & Shri Manish Agarwalatotech India Private Dy. Cit, Limited, Circle-1(1), 66 Km Stone, Nh-8, Delhi Vs. Gurgaon. Jaipur Highway, Gurgaon. (Appellant) (Respondent)

basis points, and applied interest rate of 12.6% and computed adjustment of Rs. 7,27,737/- which was proposed by AO in draft assessment order. The ld. DRP directed the AO to apply 7.84% rate (Libor plus 300 basis points) and the final addition was reduced

Vinod Kumar Jangir, Jhunjhunu vs. Dct, Circle (Intl Tax), Jaipur

Appeal is allowed and the impugned assessment

ITA 779/JPR/2024[2013-14]Status: DisposedITAT Jaipur01 May 2025AY 2013-14

Bench: Shri Gagan Goyal & Shri Narinder Kumarmr. Vinod Kumar Jangir, C/O. Yashi Super Market, Vishwakarma Complex, Gandhi Chowk, Distt. Jhunjhunu -333001 Pan No. Arzpj 7960G ...... Appellant Vs.

For Appellant: Mr. R. S. Poonia, C.A., Ld. ARFor Respondent: Mrs. Alka Gautam, CIT, Ld. DR
Section 139(4)Section 144CSection 147Section 148Section 148ASection 69

notice u/s. 148 of the Act was issued on 25.07.2022. After detailed deliberation on the issue under consideration the AO passed a draft assessment order u/s. 144C (1) of the Act and proposed an addition of Rs. 55 Lacs. Against this draft assessment order the assessee approached the Dispute Resolution ... directions issued by the DRP u/s. 144C (5) of the Act preferred the present appeal before us. 3. We have gone through the draft assessment order passed u/s. 144C (3), directions of the DRP u/s. 144C (5) of the Act and final assessment order passed u/s. 147 r.w.s. 144C