“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

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

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

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

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

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

We Are Voices Entertainment Inc, Gurgaon vs. DCIT International Taxation 3(1)(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 1474/DEL/2022[2019-20]Status: DisposedITAT Delhi25 Jul 2023AY 2019-20

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2019-20

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri Vizay Vasanta, CIT-DR

Section 143(3)Section 195Section 234ASection 270A

along with detailed questionnaire were issued to which the assessee responded by filing necessary information and details electronically. 3.2 The Ld. AO passed draft assessment order on 30.09.2021 under section 143(3) r.w.s. 144C of the Act proposing to tax the income received by the assessee from the Customer

DCIT, Circle- 2(2)(1), Intl. Taxation, New Delhi vs. Mondon Investments Ltd., New Delhi

In the result, appeal is dismissed

ITA 4014/DEL/2018[2013-14]Status: DisposedITAT Delhi25 Jul 2023AY 2013-14

Bench: Shri G.S. Pannu & Shri Saktijit Dey, Vice-Assessment Year: 2013-14 Dcit, Circle 2(2)(1), Versus Mondon Investments Ltd., International Taxation, C/O Khiwani & Co., Cas, New Delhi. East Patel Nagar, Main Market, New Delhi. Pan: Aafcm8386H (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Adv. & Sh. Deepesh Garg, Adv. Revenue By : Sh. Vizay B. Vasanta, Cit/Dr

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Sh. Vizay B. Vasanta, CIT/DR

Section 143(3)Section 144CSection 144C(1)Section 144C(15)Section 144C(3)Section 292BSection 92C

variation to 4 the income returned by the assessee is proposed, which is prejudicial to the assessee, a draft assessment order in terms of section 144C(1) of the Act was required to be passed. Accordingly, on 09.11.2016, he passed a draft assessment order, purportedly, under section 143(3) read ... with section 144C(1) of the Act. Since, the assessee did not raise any objections against the draft assessment order within the statutory period of limitation, the Assessing Officer passed the final assessment order on 19.01.2017 under section 143(3) read with section 144C(3) of the Act determining total

Ramanan Sivaraman Eranath Vengali, Mumbai vs. Income Tax Officer Int Tax Ward 2(2)(1), Mumbai

Accordingly, the addition of INR 97,32,625/- made by the Assessing Officer is deleted and Ground No. 2 to 4 are allowed in terms of the aforesaid

ITA 807/MUM/2023[2015-16]Status: DisposedITAT Mumbai21 Jul 2023AY 2015-16

For Appellant: Shri Rajendra Kumar JainFor Respondent: Shri Anil Sant

Section 143(3)Section 144C(13)Section 144C(5)Section 148Section 56

while farming the order. 7. The Ld. Dispute Resolution Panel has erred in not considering the grounds raised by the Assessee against the draft assessment order dated 04.03.2022 passed by the Assessing Officer and same were also not considered by the Ld.AO inspite of the fact that they were raised ... hands of the Appellant as income and proposed an addition of INR 11,62,625/- in the hands of the Appellant vide Draft Assessment Order, dated 04/03/2022, passed under Section 144C read with Section 147 of the Act. The Appellant, through authorized representative filed objections against the Draft Assessment Order

Viney Corporation Limited, New Delhi vs. ACIT, New Delhi

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

ITA 1409/DEL/2021[2015-16]Status: DisposedITAT Delhi21 Jul 2023AY 2015-16

Bench: Shri Kul Bharat & Shri M.Balaganesh[Assessment Year : 2015-16] Viney Corporation Ltd., Vs Acit, E-872, 1St Floor, Saraswati Vihar, Circle-26(2), Pitampura, New Delhi-110034. New Delhi. Pan-Aaacv0446L Appellant Respondent Appellant By Shri R.K.Kapoor, Ca Respondent By Ms. Swati Joshi, Cit Dr Date Of Hearing 30.05.2023 Date Of Pronouncement 21.07.2023

Section 143(3)Section 154Section 32(1)(iia)

with its Associate Enterprise (“AE”). Accordingly, the issue was referred to Transfer Pricing Officer (“TPO”). On the basis of recommendation of TPO, a draft assessment order was passed u/s 143(3)/144C of the Act on 31.12.2018. The assessee filed its objection before Ld. Dispute Resolution Panel (“DRP”). In respect

Mahindra & Mahindra Limited, Mumbai vs. Addl/Jt/Dy/ACIT/ITO, National E- Assessment Centre, Delhi/Local Jurisdictional Assessing Officer Is Asstt, CIT- CC-2(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 1058/MUM/2021[2016-17]Status: DisposedITAT Mumbai20 Jul 2023AY 2016-17

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Additional/Joint/Deputy/Assistant Commissioner Of Income Tax/ Mahindra & Mahindra Income Tax Officer, National E- Limited Assessment Centre, Delhi Corporate Taxation, Local Jurisdictional Assessing P.K.Kurne Chowk, Vs. Worli, Officer Mumbai-400 018 Asst. Commissioner Of Income Tax, Circle 2(2)(1), Mumbai (Appellant) (Respondent) Pan No. Aaacm3025E Assessee By : Shri H.P. Mahajani, Ar Revenue By : Shri Manoj Kumar, Cit Dr Date Of Hearing: 18.07.2023 Date Of Pronouncement : 20.07.2023

For Appellant: Shri H.P. Mahajani, ARFor Respondent: Shri Manoj Kumar, CIT DR

Section 143Section 143(3)Section 144(3)Section 144CSection 144C(13)Section 153Section 153(1)Section 92C

November, 2019, wherein the total adjustment to the Arms Length Price was proposed to ₹32,06,92,286/-. The learned Assessing Officer passed draft assessment order under Section 143(3) read with section 144C (1) of the Act on 28th December, 2019, wherein the total income of the assessee ... wherein the adjustment on account of Arm’s Length Price of international transaction was also included. Against the draft Assessment order, assessee preferred the objection before the learned Dispute Resolution Panel. The learned Dispute Resolution Panel passed direction on 26th March, 2021. Based on this, the final assessment order

Crisil Ltd (in the Matter of Erstwhile Pipal Research Analytics and Information Services India P.Ltd, Mumbai vs. Asst CIT 9(2)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5029/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Jul 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Crisil Ltd. (In The Matter Of Erstwhile Pipal Research Analytics &Information Services Acit 9(2)(2) India Pvt. Ltd. Merged With Crisil Aaykar Bhavan, M. K. Road, Vs. Ltd.) Mumbai-400020 Crisil House, Central Avenue Road, Hiranndani Business Park,Powai Mumbai-400076 (Appellant) (Respondent) Pan No. Aaics2386Q

For Appellant: Ms. Chandani Shah, ARFor Respondent: Shri. Vachaspati Tripathi, DR

Section 143Section 144C(13)Section 92

despite the above intimation to the learned Assessing Officer on 22nd September, 2016 and 21, December, 2016, the learned Assessing Officer passed the draft assessment order on 26th December, 2016 in the name of Pipal Research Analytics and Information Services India Pvt. Ltd. The assessee preferred the objection before ... learned Dispute Resolution Panel also, the assessee has stated the fact of the merger. Despite above facts, the learned Assessing Officer passed the draft assessment order and learned Dispute Resolution Panel issued directions in the name of a non-existent entity. Consequently, the learned Assessing Officer passed final assessment order

Hitachi, Ltd., New Delhi vs. ACIT, Circle International Taxation 2(1) (1), New Delhi

In the result, assessee’s appeals being ITA no

ITA 2260/DEL/2022[2019-20]Status: DisposedITAT Delhi19 Jul 2023AY 2019-20

Bench: Shri Shamim Yahya & Shri Kul Bharat[A.Y.: 2018-19] & [A.Y.: 2019-20]

Section 143(3)Section 144C(13)Section 270A

shore supply made by the assessee during the year under consideration. After considering the submissions of the assessee the AO passed a draft assessment order, whereby he proposed addition of Rs. 50,42,987/- to the returned income. Aggrieved against this the assessee preferred its objections before the learned Dispute

Hitachi, Ltd., Delhi vs. ACIT, Circle International Taxation.2(1)(1), New Delhi

In the result, assessee’s appeals being ITA no

ITA 2259/DEL/2022[2018-19]Status: DisposedITAT Delhi19 Jul 2023AY 2018-19

Bench: Shri Shamim Yahya & Shri Kul Bharat[A.Y.: 2018-19] & [A.Y.: 2019-20]

Section 143(3)Section 144C(13)Section 270A

Shree Raj Foundation, Mum vs. DDIT (E)-I(2), Mum

In the result, the appeal of the assessee is allowed

ITA 18/MUM/2023[2009-10]Status: DisposedITAT Mumbai18 Jul 2023AY 2009-10

Bench: Shri Aby T. Varkey, Jm & Shri Om Prakash Kant, Am आयकर अपील सं/ I.T.A. No.18/Mum/2023 (निर्धारण वर्ा / Assessment Years: 2009-10) Shree Raj Foundation बिधम/ Ddit(E)-1(2) 201, 2Nd Floor, Krishna [Now Ito (Exem), Ward- Vs. Kunj, Vl Mehta Rd, Jvpd 2(3), Mumbai] Scheme, Vile Parle (W), Income Tax Office, Mumbai-400056. Mtnl Building, Peddar Road, Mumbai-400026. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aadts9658M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Paresh Shaparia Revenue By: Shri Anil Kumar Das (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 30/06/2023 घोषणा की तारीख /Date Of Pronouncement: 18/07/2023 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Foundation Against The Order Of The Ld. Commissioner Of Income Tax/Nfac, Delhi Dated 02.12.2022 For Assessment Year 2009-10. 2. At The Outset, The Ld. Ar Of The Assessee Has Challenged The Action Of The Ao Re-Opening The Assessment Of Ay 2009-10 U/S 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”) Without Following The Binding Decision Of The Hon’Ble Supreme Court In The Case Of Gkn Driveshafts (India) Ltd. Vs. Ito (Sc) (259 Itr 19) & Jurisdictional High Court Decision In The Case Of Fomento Resorts Hotels Ltd Vs. Acit (238 Itr 38) (Bom) & Asian Paints Ltd. Vs. Dcit (2008) (296 Itr 90) (Bom). 3. The Facts Relevant To The Legal Issue Are That The Assessee Had Filed Its Return Of Income On 30.09.2009 Along With The Income & Expenditure Account, Balance-Sheet & Audit Report In Form No. 10B

For Appellant: Shri Paresh ShapariaFor Respondent: Shri Anil Kumar Das (Sr. AR)

Section 11Section 12ASection 143(3)Section 147Section 148

Assessee lodged objections to the reasons on 25th March, 2015. The Assessing Officer, without disposing of the Petitioner’s objections, made a draft assessment order dated 30th March, 2015, since this was a matter involving transfer pricing. In such circumstances, the Division Bench of this Court, set aside the assessment ... furnished to the Assessee. This Court held that the proceedings initiated by the Transfer Pricing Officer (TPO), on the basis of such a draft assessment order, were without jurisdiction and quashed the same. 21. Similarly, in the case of KSS Petron Private Ltd. (supra), this Court was concerned with

Frost & Sullivan (India) P.Ltd, Mumbai vs. DCIT Cir 9(3)(2), Mumbai

In the result, appeal of the assessee is allowed and appeal of the Revenue is dismissed

ITA 1259/MUM/2015[2010-11]Status: DisposedITAT Mumbai18 Jul 2023AY 2010-11

Section 143(3)Section 144C(5)Section 153Section 92Section 92C

officer (Ld. TPO') 3 Date of order u/s 92CA(3) of the ITA 30-01-2014 passed by Ld. TPO 4 Date of draft assessment order passed by 05-03-2014 Ld. AO u/s 143(3) r.w.s. 144C(1) of the ITA 5 Date of direction u/s 144C ... time barred in terms of section 92CA(3) of the Act read with Section 153) and consequently, the passing of draft assessment order and the entire proceedings initiated u/s 144C is bad in law, because in absence of valid TPO order, the assessee ceases to be an eligible assessee

DCIT 9(3)(2), Mumbai vs. Frost and Sullivan (India) P.Ltd, Mumbai

In the result, appeal of the assessee is allowed and appeal of the Revenue is dismissed

ITA 1148/MUM/2015[2010-11]Status: DisposedITAT Mumbai18 Jul 2023AY 2010-11

Section 143(3)Section 144C(5)Section 153Section 92Section 92C

Shri Darshan Pal Singh Garewal, Ludhiana vs. Deputy Commissioner of Incme Tax Central Circle-1, Jalandhar

In the result, the appeal of the assessee is allowed

ITA 389/ASR/2019[2013-14]Status: DisposedITAT Amritsar18 Jul 2023AY 2013-14

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: None (Written submission)For Respondent: Smt. Ratinder Kaur, Sr. DR

Section 132Section 153ASection 153DSection 271Section 271A

dated 21.06.2023 granted relief vide para 10, 11 & 13 which reads as under: “10. In the instant cases, the AO has submitted the draft assessment order on 20/03/2015 before the Approving Authority who had approved on same day i.e. 4 Darshan Pal Singh Garewal v. Dy. CIT 20/03/2015

Madhurittu Puri, United Kingdom vs. DCIT, Circle International Taxation 2(2)(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 3063/DEL/2022[2019-20]Status: DisposedITAT Delhi18 Jul 2023AY 2019-20

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2019-20

For Appellant: Shri Sanjiv Sapra, FCAFor Respondent: Shri Vizay Vasanta, CIT- DR

Section 142ASection 143(3)Section 144Section 234DSection 270A(2)

assessee resulting in addition of Rs. 2,23,23,116/- to the income of the assessee. 3.2 Accordingly, the Ld. AO passed a draft assessment order under section 144(C)(1) r.w.s 143(3) of the Act on 23.02.2022. 3.3 On receipt of the said draft assessment order, the assessee ... speaking order. 3.4 It is apparent from page 5 of the Ld. AO’s order that he maintained the addition proposed in draft assessment order and completed the assessment on 20.12.2022 under section 143(3) r.w.s. 144C (13) of the Act on total income

Bushra Javed, New Delhi vs. ACIT, Circle Int. Taxation 2(1)(2), New Delhi

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

ITA 2003/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Jul 2023AY 2018-19

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2018-19 Bushra Javed, Vs. Acit, D-112, Circle Int. Taxation 2 Lower Ground Floor, (1)(1) Panchsheel Enclave, New Delhi. New Delhi-110 017 Pan Afgpj3907C (Appellant) (Respondent)

For Appellant: Shri Manish, CAFor Respondent: Shri Vizay Vasanta, CIT- DR

Section 143(3)Section 144CSection 48

Del/2022 21.08.2018 declaring income of Rs. 45,290/-. Her case was selected under complete scrutiny. In his draft assessment order dated 25.09.2021 under section 144C of the Act. The Ld. AO computed the long term capital gain of Rs. 19,47,875/- as against Rs. 5,294/- declared ... income of the assessee. 3.1 The assessee raised objections with the Ld. Dispute Resolution Panel (“DRP”) to the draft assessment order. After hearing the assessee, the Ld. DRP issued directions vide order under section 144C of the Act on 09.05.2022. In para 4.1 of its directions, the Ld. DRP observed

Michael Graves Design Group Inc., Usa vs. DCIT, Circle- 2(2)(1), Intl. Taxation, New Delhi

In the result, the appeals of the assessee for both the AYs i

ITA 6007/DEL/2018[2015-16]Status: DisposedITAT Delhi18 Jul 2023AY 2015-16

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2014-15 & Asstt. Year: 2015-16

For Appellant: Shri Niraj Seth, Advocate &For Respondent: Shri Sanjay Kumar, Sr. DR

Section 115ASection 143(3)

received by the assessee is to be treated as FIS for the reasons recorded by him in para 3.2 to 3.5 of his draft assessment order dated 26.12.2016 for AY 2014-15 and 07.12.2017 for AY 2015-16. For the sake of clarity, the findings ... covered under the services, consideration from which is to be treated as 'Fees from Included Services'. 6.3 The assessee filed objections to the draft assessment order before the Ld. Dispute Resolution Panel (“DRP”). The Ld. DRP after considering the submissions of the assessee and the relevant clauses of the agreement

Michael Graves Design Group Inc., Usa vs. DCIT, Circle- 2(2)(1), Intl. Taxation, New Delhi

In the result, the appeals of the assessee for both the AYs i

ITA 7683/DEL/2017[2014-15]Status: DisposedITAT Delhi18 Jul 2023AY 2014-15

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2014-15 & Asstt. Year: 2015-16

For Appellant: Shri Niraj Seth, Advocate &For Respondent: Shri Sanjay Kumar, Sr. DR

Section 115ASection 143(3)

M/S. Bridgestone India Pvt. Ltd., Pune vs. The ACIT NFAC, Delhi

In the result, appeal of assessee is partly allowed

ITA 84/IND/2022[2017-18/]Status: DisposedITAT Indore17 Jul 2023

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanibridgestone India Pvt. Ltd. Acit (Nfac) Plot No.A-43, Phase-Ii, Delhi Midc Chakan, Village Vs. Sawardari, Taluka Khed, Pune (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcb 2304 E Assessee By Shri Sukhsagar Syal, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 23.05.2023 Date Of Pronouncement 17.07.2023

Section 143(3)Section 144C(13)Section 144C(5)Section 43(1)

State Government to the assesse it is clear that the said amount of subsidy is revenue in nature. Accordingly the AO issued a draft assessment order on 01.04.2021 and proposed to make the addition of the entire amount of subsidy received by the assesse as revenue receipt. Page ... well as CIT vs. Ponni Sugars & Chemicals Ltd. 306 ITR 392 (SC). The assesse filed objectionS against the draft assessment order before the DRP. The DRP has confirmed the draft assessment order and rejected objections filed by the assesse while passing direction u/s 144C

M/S. Bombardier Transportation Gmbh, New Delhi vs. DCIT, New Delhi

In the result, the appeal is allowed, as indicated above

ITA 1390/DEL/2015[2010-11]Status: DisposedITAT Delhi14 Jul 2023AY 2010-11

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2010-11

Section 144C(13)

offshore and onshore supplies and services to the alleged PE of the assessee in India in the form of project office. Against the draft assessment order so passed, the assessee raised objections before learned DRP. 6. While dealing with assessee’s objection, learned DRP granted substantial relief to the assessee

Alliance One Industries India Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax Circle 1(1), Guntur

In the result, appeal of the assessee is partly allowed

ITA 68/VIZ/2022[2017-2018]Status: DisposedITAT Visakhapatnam14 Jul 2023AY 2017-2018

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri K.C. Devdas, ARFor Respondent: Sri MN Murthy Naik, CIT-DR

Section 143(1)Section 143(2)Section 143(3)Section 92C

therefore made an upward adjustment of Rs. 14,41,14,891/- to the returned income of the assessee. Accordingly, the draft assessment order U/s. 144C(1) of the Act was passed on 24/03/2021 by the Ld. AO. Against the draft order, the assessee filed its objections before the Ld. Dispute

Buro Happold Limited, Mumbai vs. Deputy Commissioner of Income Tax, International Taxation-1(3)(2), Mumbai

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

ITA 1006/MUM/2023[2020-2021]Status: DisposedITAT Mumbai13 Jul 2023AY 2020-2021

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Rahul Chaudhary, Hon'Bleburo Happold Limited V. Acit (International Tax) C/O. Sudit K. Parekh & Co. Llp Circle – 1(3)(2) Urmi Estate – Tower A, 20Th Floor Room No. 1810, 18Th Floor 95, Ganpatrao Kadam Marg Air India Building Nariman Point, Mumbai – 400 021 Lower Parel (W), Mumbai – 400013 Pan: Aabcb9239Q (Appellant) (Respondent)

Section 144C(5)Section 234BSection 90(2)

challenge the order of DRP in an appeal. On this ground, the ld. DRP upheld the action of the ld. AO in the draft assessment order. 5. Pursuant to the directions of the ld. DRP, the ld. AO passed the final assessment order u/s 143(3) rws 144C