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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

Edenred Se (Formerly Known As Edenred Sa, Mumbai vs. Dy. Comm of Income Tax International Taxation-2(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 1563/MUM/2022[2019-20]Status: DisposedITAT Mumbai04 Aug 2023AY 2019-20

Bench: Shri Vikas Awasthi () & Ms. Padmavathy S. ()

Section 143(3)Section 144C(13)

issue and held that:- “8. We have heard the rival submissions and perused the material available on record. In the present case, vide draft assessment order, the AO held that TSIS Service Fee received by the assessee is taxable as royalty, while the Management Service Fee is taxable as fees ... support and maintenance services, development services, infrastructure and security services, and professional services proposed by the assessee to the Indian group companies. Vide draft assessment order, the AO held that the assessee and its Indian group companies are in the same business of managing prepaid CHM/CRM, rewards, loyalty, and marketing

Piyush Mathur, Banglore vs. ACIT Circle Int. Tax 2(2)(1), New Delhi

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

ITA 351/DEL/2023[2020-21]Status: DisposedITAT Delhi04 Aug 2023AY 2020-21

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2020-21

For Appellant: Shri Piyush Kumar MathurFor Respondent: Shri Vizay B. Vasanta, CIT- DR
Section 10Section 143(3)Section 144C(1)Section 144C(2)(b)Section 17(2)Section 9(1)(i)

assessee’s claim of exemption of Rs. 62,49,989/- under section 10(10CC) added the same to his income in the proposed draft assessment order passed on 17.03.2022 under section 144C(1) r.w. section 143(3) of the Act. 7. The assessee filed objections before the Ld. Dispute Resolution

Egis International S.A., New Delhi vs. ACIT, Circle-Int. Tax 1(2)(2), New Delhi

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

ITA 1663/DEL/2021[2016-17]Status: DisposedITAT Delhi03 Aug 2023AY 2016-17

Bench: Shri M. Balaganesh & Ms. Astha Chandraasstt. Year: 2016-17 Egis International S.A. Vs. Acit T-305, Tf, Circle-1Nt. Tax 1(2)(2) Tirupati Plaza, New Delhi. Sector-11 (Mlu), Pocket 4, Plot No. 11 Dwarka, New Delhi – 110 075. Pan Aabcb7760L (Appellant) (Respondent)

For Appellant: Shri Nageswar Rao, AdvocateFor Respondent: Shri Manu Chaurasia, Sr. DR
Section 92C(3)

proposing the cumulative adjustment of Rs. 2,28,49,247/-. Accordingly, the Ld. AO served upon the assessee a draft assessment order requiring the assessee to submit its response under section 144C(2) of the Act. The assessee neither filed any objections before Hon’ble DRP nor submitted any reply

Bridge India Fund, New Delhi vs. ACIT (Int Tax) Circle-1(3)(2), Mumbai

In the result ITA number 457/M/2023 for assessment year 2014 – 15 is partly allowed for statistical purposes

ITA 458/MUM/2023[2015-16]Status: DisposedITAT Mumbai01 Aug 2023AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri S. Krishnan, ARFor Respondent: Shri Soumendu Kumar Das, DR
Section 142(1)Section 144Section 147

obtaining the total purchase transaction of the above company chargeable to tax under section 69C of the act. Accordingly the draft assessment order was passed. 09. The assessee approached the learned Dispute Resolution Panel against the draft assessment order. The learned dispute resolution panel passed an order under section 144C ... assessee, holding it as not maintainable and therefore confirmed the order of the learned assessing officer. 012. The fact shows that after the draft assessment order was passed for assessment year 2014 – 15, assessee filed objections to the draft order in form number 35A (under rule 4 (1) before

Bridge India Fund, New Delhi vs. ACIT (Int Tax) Circle-1(3)(2), Mumbai

In the result ITA number 457/M/2023 for assessment year 2014 – 15 is partly allowed for statistical purposes

ITA 457/MUM/2023[2014-15]Status: DisposedITAT Mumbai01 Aug 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri S. Krishnan, ARFor Respondent: Shri Soumendu Kumar Das, DR
Section 142(1)Section 144Section 147

obtaining the total purchase transaction of the above company chargeable to tax under section 69C of the act. Accordingly the draft assessment order was passed. 09. The assessee approached the learned Dispute Resolution Panel against the draft assessment order. The learned dispute resolution panel passed an order under section 144C ... assessee, holding it as not maintainable and therefore confirmed the order of the learned assessing officer. 012. The fact shows that after the draft assessment order was passed for assessment year 2014 – 15, assessee filed objections to the draft order in form number 35A (under rule 4 (1) before

Kraft Heinz Foods Company, Mumbai vs. DCIT (It) 2(2)(2), Mumbai

In the result, both the appeals of the assessee for A

ITA 2017/MUM/2017[2013-14]Status: DisposedITAT Mumbai01 Aug 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Manthan Shah, ARFor Respondent: Ms. Surabhi Sharma, CIT DR
Section 143Section 143(3)Section 144CSection 144C(13)Section 271(1)Section 271(1)(c)Section 9(1)(v)Section 9(1)(vii)

chargeable tax at the rate of 15%. Thus, the total income was assessed at ₹10,17,16,749/- by passing the draft assessment order under Section 144C of the Act on 12th March, 2014. 03. The assessee approached to the learned Dispute Resolution Panel-1, New Delhi, who passed

Amazon Web Services, Inc., Usa vs. ACIT Circle International Tax 1(1)(1), New Delhi

Accordingly, ground No. 3 along with its sub-grounds 3.1 to 3.4, ground No. 4 and ground No. 5 along with its sub-ground 5.1 r.w ground No. 2 are allowed

ITA 523/DEL/2023[2016-17]Status: FixedITAT Delhi01 Aug 2023AY 2016-17

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 144CSection 147Section 151Section 201Section 9(1)(vi)

DTAA. The submissions of the assessee were considered but not found tenable by the Ld. AO. The Ld. AO proceeded to pass the draft assessment order on 31.03.2022 proposing to tax the entire receipts ... under the Act as well as India-USA DTAA. 4. The assessee filed objections before the Ld. Dispute Resolution Panel (“DRP”) against the draft assessment order passed by the Ld. AO. The Ld. DRP upheld the initiation of re-assessment proceedings and confirmed the additions proposed in the draft assessment

Amazon Web Services, Inc., Usa vs. ACIT, Circle-1(1)(1), New Delhi

Accordingly, ground No. 3 along with its sub-grounds 3.1 to 3.4, ground No. 4 and ground No. 5 along with its sub-ground 5.1 r.w ground No. 2 are allowed

ITA 522/DEL/2023[2014-15]Status: FixedITAT Delhi01 Aug 2023AY 2014-15

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 144CSection 147Section 151Section 201Section 9(1)(vi)

DTAA. The submissions of the assessee were considered but not found tenable by the Ld. AO. The Ld. AO proceeded to pass the draft assessment order on 31.03.2022 proposing to tax the entire receipts ... under the Act as well as India-USA DTAA. 4. The assessee filed objections before the Ld. Dispute Resolution Panel (“DRP”) against the draft assessment order passed by the Ld. AO. The Ld. DRP upheld the initiation of re-assessment proceedings and confirmed the additions proposed in the draft assessment

Kraft Heinz Foods Company( Earlier Known As H.J.Heinz Company), Mumbai vs. DDIT(It)-2(2)(2), Mumbai

In the result, both the appeals of the assessee for A

ITA 2694/MUM/2016[2012-13]Status: FixedITAT Delhi01 Aug 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Manthan Shah, ARFor Respondent: Ms. Surabhi Sharma, CIT DR
Section 143Section 143(3)Section 144CSection 144C(13)Section 271(1)Section 271(1)(c)Section 9(1)(v)Section 9(1)(vii)

chargeable tax at the rate of 15%. Thus, the total income was assessed at ₹10,17,16,749/- by passing the draft assessment order under Section 144C of the Act on 12th March, 2014. 03. The assessee approached to the learned Dispute Resolution Panel-1, New Delhi, who passed

Hunt International Investments Llc, Mumbai vs. DCIT, Circle Int Taxation, 2(1)(1), New Delhi

In the result, impugned order is set-aside and the appeal is allowed for statistical purposes

ITA 916/MUM/2023[2015-2016]Status: DisposedITAT Mumbai31 Jul 2023AY 2015-2016

Bench: Shri Vikas Awasthy & Ms. Padmavathy Sआअसं. 916/मुं/2023 (िन.व. 2015-16) Hunt International Investments Llc 205-206, Regent Chambers, 2Nd Floor, Jamnalal Bajaj Road, 208, Nariman Point, Mumbai-400021. Pan: Aadch0520J ...... अपीलाथ" /Appellant बनाम Vs. Dcit, Circle International Taxation-2(1)(1), Civic Centre, Minto Road, New Delhi-110002. ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Sh. A.N. Shah "ितवादी "ारा/Respondent By : Sh. Anil Sant, Sr. Dr सुनवाई की ितिथ/ Date Of Hearing : 31/07/2023 घोषणा की ितिथ/ Date Of Pronouncement : 31/07/2023 आदेश/ Order Per Vikas Awasthy, Jm This Appeal By The Assessee Is Directed Against The Assessment Order Dated 27.01.2023 Passed Under Section 144C(13)/143(3) R.W.S. 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’), For The Assessment Year 2015-16. 2. Sh. A.N. Shah Appearing On Behalf Of The Assessee Submitted That The Assessee Is A Tax Resident Of Usa. The Assessee Is A Registered Foreign Portfolio Investor [Category-Iii]. The Assessee Primarily Invests In Shares To Earn Long Term

For Appellant: Sh. A.N. ShahFor Respondent: Sh. Anil Sant, Sr. DR
Section 10(38)Section 142(1)Section 144Section 144C(13)Section 148

issued notices under section 142(1) on 03.02.2022 and 22.03.2022, the said notices were never received by the assessee. The AO passed the draft assessment order on 30.03.2022 rejecting assessee’s claim of exemption u/s 10(38) of the Act. The assessee could not make proper submissions before ... receipt of the notices. Even the draft assessment order was not received by the assessee in time. As soon as the assessee came to know about the draft assessment order, the assessee filed objections before the DRP. However, the DRP dismissed the objections of assessee on the ground of limitation

Thermo Fisher Scientific India Pvt Ltd., Mumbai vs. DCIT-15(3)(1), Mumbai

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

ITA 769/MUM/2023[2009-10]Status: DisposedITAT Mumbai31 Jul 2023AY 2009-10

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2009-10 Thermo Fisher Scientific India Dy. Cit-15(3)(1), Pvt. Ltd., Room No. 360, Aayakar Vs. 403-404, ‘B’ Wing, Delphi, Bhavan, New Marine Lines, Hiranandani Business Park, Mumbai-400020. Mumbai-400076. Pan No. Aabct 3207 A Appellant Respondent

For Appellant: Mr. Niraj ShethFor Respondent: Mr. Mudit Nagpal, CIT-DR
Section 43(1)

adjudicating the issue of depreciation on goodwill on merits. depreciation on goodwill on merits. 4.6 In the second round, the AO passed a draft assessment order In the second round, the AO passed a draft assessment order In the second round, the AO passed a draft assessment order dated ... Fisher Scientific India Pvt. Ltd. 4.8 Based on above ove reasoning, depreciation on goodwill was reasoning, depreciation on goodwill was disallowed in the draft assessment order. disallowed in the draft assessment order. Against the draft Against the draft assessment order, the assessment order, the assessee filed objections before

ACIT-1(1)(1), Mumbai vs. M/S Alok Kumar Agrawal, Irp of M/S. Cox and Kings Ltd, Mumbai

ITA 571/MUM/2023[2011-12]Status: DisposedITAT Mumbai31 Jul 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm M/S Alok Kumar Agrawal, Insolvency Resolution Acit-(1)(1)(1) Professional Of M/S Cox & 533/ 579A, Kings Aaykar Bhavan, Mk Road, Vs. 605, Suncity Business Tower, Mumbai-400 020 Gold Course Road, Sector-54, Gurugram, Haryana-400 020 (Appellant) (Respondent) Pan No. Aaacc1921B Assessee By : None Revenue By : Shri Dhiraj Kumar, Dr Date Of Hearing: 19.07.2023 Date Of Pronouncement : 31.07.2023

For Appellant: NoneFor Respondent: Shri Dhiraj Kumar, DR
Section 143(3)Section 144C(13)Section 37

into the books of accounts and shown in the balance sheet. The learned Assessing Officer made the addition of the same in the draft assessment order dated 9th March, 2015. On objections before the learned Dispute Resolution Panel, the learned Assessing Officer was directed to delete the addition. Therefore

M/S. Emerson Process Management (India) Pvt. Ltd (Sucessor in Interest for Pentair Valves and Controls Pvt Ltd, Mumbai vs. Addl/Jt/CIT/Dy/ACIT/NFAC, Mumbai

In the result, ITA number 2126/M/2022 filed by the assessee is allowed

ITA 772/MUM/2022[2017-18]Status: DisposedITAT Mumbai31 Jul 2023AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Dhanesh BafnaFor Respondent: Shri Pravin Salunkhe, Add. CIT
Section 115JSection 142Section 143(3)Section 144CSection 92C

name of Emerson Process Management (India) Pvt. Ltd under Section 143(3) read with section 144C (13) of the Act, however, the draft assessment order, Transfer pricing Assessment order and Direction of Dispute Resolution Panel were passed in the name of Pentair Valves and Controls India Private Limited ... also framed on 31st January, 2021 in the name of Pentair Valves and Controls India Private Limited and ii Draft Assessment orders dated 13/04/2021 is also passed in the name of Pentair Valves and Controls India Private Limited iii The direction of the Dispute Resolution Panel under Section 144C

Massachusetts Institute of Technology, Cambridge vs. DCIT Int Tax Circle 3(2)(1), Mumbai

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

ITA 607/MUM/2022[2018-19]Status: DisposedITAT Mumbai31 Jul 2023AY 2018-19
Section 143(3)Section 144C(13)Section 234ASection 234BSection 234DSection 270A

fees to tax as FIS under Article 12(4) of US-India DTAA. 9 M/s. Massachnsetts Institute of Technology 6. Aggrieved by the Draft Assessment Order issued by the ld. AO, assessee approached the Ld. DRP. The ld. DRP has rejected the arguments and rebuttals put forth by the assessee ... ONGC vs. ITO dated 3 August 2022 [ITA Nos. 1881-1882/Ahd/2019]. 18 M/s. Massachnsetts Institute of Technology 21. AO in his draft assessment order has observed that, as per the nature of programme MIT design systems that are appropriate and customized to the needs of the clients, with

M/S. Emerson Process Management (India) Pvt. Ltd (Sucessor in Interest for Pentair Valves and Controls Pvt Ltd, Mumbai vs. Addl/Jt/CIT/Dy/ACIT/NFAC, Mumbai

In the result, ITA number 2126/M/2022 filed by the assessee is allowed

ITA 2126/MUM/2022[2018-19]Status: DisposedITAT Mumbai31 Jul 2023AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Dhanesh BafnaFor Respondent: Shri Pravin Salunkhe, Add. CIT
Section 115JSection 142Section 143(3)Section 144CSection 92C

name of Emerson Process Management (India) Pvt. Ltd under Section 143(3) read with section 144C (13) of the Act, however, the draft assessment order, Transfer pricing Assessment order and Direction of Dispute Resolution Panel were passed in the name of Pentair Valves and Controls India Private Limited ... also framed on 31st January, 2021 in the name of Pentair Valves and Controls India Private Limited and ii Draft Assessment orders dated 13/04/2021 is also passed in the name of Pentair Valves and Controls India Private Limited iii The direction of the Dispute Resolution Panel under Section 144C

Executive Trading Co. Pvt Ltd., Ahmedabad vs. Comm of Income Tax (A), NFAC, Delhi

ITA 281/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 Jul 2023AY 2017-18
For Appellant: Shri Vijay MehtaFor Respondent: Shri Biswanath Das
Section 142(1)Section 144BSection 147Section 148Section 69C

submission of the Appellant. The Assessing Officer rejected the request of the Appellant to drop the reassessment proceedings and proceed to pass a Draft Assessment Order, dated 23.09.2021. In response to the same, the Appellant filed submission dated 24/09/2021. On 27/09/2021 copy of reasons recorded for re-opening assessment

Nikon India P.Ltd, Gurgaon vs. ACIT, Circle-3(1), Gurgaon

In the result, the appeal of the assessee is partly allowed and the Stay

ITA 1800/DEL/2022[2017-18]Status: DisposedITAT Delhi27 Jul 2023AY 2017-18

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Assessment Year: 2017-18 & Stay Application No.256/Del/2022 (Ita No.1800/Del/2022) Assessment Year: 2017-18 Nikon India Pvt. Ltd., Vs Acit, Plot No.71, Sector-32, Circle-3(1), Institutional Area, Gurgaon. Gurgaon, Haryana – 122001. Pan: Aaccn5100F (Appellant) (Respondent) Assessee By : Shri Vishal Kalra & Shri Ankit Sahani, Advocates; & Shri Yishu Goel, Ar Revenue By : Shri Rajesh Kumar, Cit-Dr Date Of Hearing : 19.07.2023 Date Of Pronouncement : 27.07.2023 Order Per M. Balaganesh, Am: The Appeal In Ita No.1800/Del/2022 & The Stay Application In Sa No.256/Del/2022 Filed By The Assessee Arise Out Of The Order Of Assessment Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 Sa No.256/Del/2022 (Hereinafter Referred To As ‘The Act’) Dated 25.07.2022 By The Assessment Unit, Of The Income Tax Department (Hereinafter Referred To As ‘Ld. Ao’).

For Appellant: Shri Vishal Kalra &For Respondent: Shri Rajesh Kumar, CIT-DR
Section 143(3)Section 144C(5)Section 92C

Method 71,45,33,227 (RBW )- Intensity Test Protective Bright Line Test (BLT) 127,52,94,223 7. The ld. AO passed a draft assessment order u/s 143(3) of the Act on 23.09.2021 by making an addition of Rs.71,45,33,227/- in respect of TP adjustment on account

Wns Global Services Private Limited, Mumbai vs. Assistant Comm. of Income Tax -14(1)(2), Mumbai

ITA 2451/MUM/2022[2017-18]Status: DisposedITAT Mumbai26 Jul 2023AY 2017-18

Bench: Vikas Awasthy () & Ms. Padmavathy S. ()

Section 143(1)Section 143(3)Section 14ASection 234CSection 43BSection 92C

business rights - Rs. 10,20,00,702/- 2. Interest on deemed loan -Rs. 6,53,02,720/- The Assessing Officer passed the draft assessment order incorporating the transfer pricing adjustment. Besides the transfer pricing adjustment, the Assessing Officer also made a disallowance under section 14A to the tune of Rs.5

Wns Global Services Private Limited, Mumbai vs. Assistant Comm. of Income Tax-14(1)(2), Mumbai

ITA 2450/MUM/2022[208-2019]Status: DisposedITAT Mumbai26 Jul 2023

Bench: Vikas Awasthy () & Ms. Padmavathy S. ()

Section 143(1)Section 143(3)Section 14ASection 234CSection 43BSection 92C

business rights - Rs. 10,20,00,702/- 2. Interest on deemed loan -Rs. 6,53,02,720/- The Assessing Officer passed the draft assessment order incorporating the transfer pricing adjustment. Besides the transfer pricing adjustment, the Assessing Officer also made a disallowance under section 14A to the tune of Rs.5

Franklin Wardcorpp India Pvt. Ltd., Mumbai vs. Addll./Jt/ACIT, NFAC, Delhi

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

ITA 2487/MUM/2021[2017-18]Status: DisposedITAT Mumbai26 Jul 2023AY 2017-18

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

For Appellant: Shri Ashok Rao &For Respondent: Ms. Vranda U. Matkari, DR
Section 143(3)Section 144BSection 144C(13)

Order under Section 92CA (3) of the Act was passed on 1st November, 2019. Based on this, the draft assessment order was passed on 19th December, 2019. 05. Assessee preferred the objection before the learned Dispute Resolution Panel, who passed direction on 18th March, 2021. The directions were further rectified