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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

Measeg. Ladakh Roadlines, Srinagar vs. Assistant Commissioner of Income Tax Circle, Srinagar

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

ITA 295/ASR/2019[2015-16]Status: DisposedITAT Amritsar24 Feb 2023AY 2015-16

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

Section 143(2)Section 143(3)Section 144Section 145(3)Section 250Section 282

that the assessment order U/s 144 dt.26/10/2017 is illegal in view of inadequate or no opportunity provided to the appellant & non-service of draft assessment order upon the appellant before its passing. 3. In placing undue reliance on assumptions & presumptions on the basis of which the notices issued have been

Srf Ltd., Gurgaon vs. Addl CIT, New Delhi

In the result, this ground of the assessee is allowed for statistical purposes

ITA 774/DEL/2017[2009-10]Status: DisposedITAT Delhi23 Feb 2023AY 2009-10

Bench: Sh. Anil Chaturvedi & Sh. Yogesh Kumar Ussrf Limited Vs. Acit Unitech Crest, Greenwood Range – 9, City Block – C, Sector – 45, Ltu, New Delhi Gurgaon – 122 003 Pan No. Aaacs 0206 P (Appellant) (Respondent) Assessee By Shri Pradeep Dinodia, Shri R. K. Kapoor C.A. Shri Ravi Kumar Revenue By Shri Mahesh Shah, Cit (Dr) Shri Rajesh Kumar, Cit (Dr) Date Of Hearing: 10/01/2023 Date Of Pronouncement: 23/02/2023 Order Per Anil Chaturvedi, Am: The Present Appeal Is Filed By The Assessee Directed Against The Order Dated 27.09.2016 Of The Commissioner Of Income Tax (Appeals)-44, New Delhi [For Short, Cit(A)] Under Section 143(3) R.W.S 144C Of The Income Tax Act, 1961 [For Short, 'The Act'] For Assessment Year 2009-10. 2. Brief Facts Of The Case As Culled Out From The Material On Record Are As Under:-

Section 143(2)Section 143(3)Section 144CSection 14ASection 92C

92CA(3) proposed enhancement of income of the assessee by Rs.36,03,975/-on account of the international transactions. AO thereafter passed a draft assessment order u/s 144C of the Act vide order dated 18.03.2013 and computed the total taxable income at Rs.168,87,52,470/-. AO has noted that ... been charged by the assessee from its AE to be Rs.36,03,975/-. Based on the adjustment suggested by TPO, AO in the draft assessment order proposed upward adjustment to the extent of Rs 36,03,975/-. Aggrieved by the order of AO, assessee carried the matter before

Vikas Gupta, Delhi vs. ACIT, Central Circle-32, Delhi

In the result, all these appeals are partly allowed

ITA 2755/DEL/2022[2019-20]Status: DisposedITAT Delhi22 Feb 2023AY 2019-20

Bench: Shri Kul Bharat

Section 143(1)Section 147Section 151

erred in upholding the same. 13. That the Ld. AO has erred in only issuing show cause notice and no draft assessment order was ever issued to the assessee and hence on this ground only, the present order has to be set aside. 14. That the appellant reserves the right ... erred in upholding the same. 13. That the Ld. AO has erred in only issuing show cause notice and no draft assessment order was ever issued to the assessee and hence on this ground only, the present order has to be set aside. 14. That the appellant reserves the right

Vikas Gupta, Delhi vs. ACIT, Central Circle-32, New Delhi

In the result, all these appeals are partly allowed

ITA 2754/DEL/2022[2018-19]Status: DisposedITAT Delhi22 Feb 2023AY 2018-19

Bench: Shri Kul Bharat

Section 143(1)Section 147Section 151

erred in upholding the same. 13. That the Ld. AO has erred in only issuing show cause notice and no draft assessment order was ever issued to the assessee and hence on this ground only, the present order has to be set aside. 14. That the appellant reserves the right ... erred in upholding the same. 13. That the Ld. AO has erred in only issuing show cause notice and no draft assessment order was ever issued to the assessee and hence on this ground only, the present order has to be set aside. 14. That the appellant reserves the right

Vikas Gupta, Delhi vs. ACIT, Central Circle-32, Delhi

In the result, all these appeals are partly allowed

ITA 2753/DEL/2022[2017-18]Status: DisposedITAT Delhi22 Feb 2023AY 2017-18

Bench: Shri Kul Bharat

Section 143(1)Section 147Section 151

erred in upholding the same. 13. That the Ld. AO has erred in only issuing show cause notice and no draft assessment order was ever issued to the assessee and hence on this ground only, the present order has to be set aside. 14. That the appellant reserves the right ... erred in upholding the same. 13. That the Ld. AO has erred in only issuing show cause notice and no draft assessment order was ever issued to the assessee and hence on this ground only, the present order has to be set aside. 14. That the appellant reserves the right

Vikas Gupta, Delhi vs. ACIT, Central Circle-32, Delhi

In the result, all these appeals are partly allowed

ITA 2752/DEL/2022[2016-17]Status: DisposedITAT Delhi22 Feb 2023AY 2016-17

Bench: Shri Kul Bharat

Section 143(1)Section 147Section 151

erred in upholding the same. 13. That the Ld. AO has erred in only issuing show cause notice and no draft assessment order was ever issued to the assessee and hence on this ground only, the present order has to be set aside. 14. That the appellant reserves the right ... erred in upholding the same. 13. That the Ld. AO has erred in only issuing show cause notice and no draft assessment order was ever issued to the assessee and hence on this ground only, the present order has to be set aside. 14. That the appellant reserves the right

ACIT, Circle-3(1)(1) Int. Taxation, New Delhi vs. Thicom Public Company Ltd., New Delhi

Appeal of the revenue is dismissed

ITA 7886/DEL/2019[2016-17]Status: DisposedITAT Delhi21 Feb 2023AY 2016-17

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaacit, Vs. Thicom Public Company Ltd, Central Circle-3(1)(1), C/O. Mohinder Puri & Co, International Taxation Cas, 1Ad, Vandhana, 11, New Delhi Tolstoy Marg, New Delhi (Appellant) (Respondent) Pan: Aagcs4481E

For Appellant: Shri Jatinder Singh, CAFor Respondent: Shri Parikshit Singh, CA
Section 143(3)Section 144C(1)Section 9

royalty within the meaning of respective articles of DTAA. Accordingly, the receipts were held to be taxable @10% under 115A as royalty. Draft assessment order dated 13.11.2018 was passed u/s 144C(1)/143(3) of the Act and communicated to the Assessee. The Assessee had not filed its objections before

John Wiley & Sons, Inc, Usa vs. DCIT International Taxation, Circle 3(1)(1), Delhi

The appeals are allowed

ITA 1873/DEL/2022[2019-20]Status: DisposedITAT Delhi20 Feb 2023AY 2019-20

Bench: Shri N. K. Billaiya & Shri Anubhav Sharma

For Appellant: Sh. Salil Kapoor & Vibhu Jain, AdvsFor Respondent: Sh. Sanjay Kumar Bharati, CIT DR

specifically directed in para 2.1 as follows:- 2.1 In regard to the above Ground, it is seen that the AO has passed the draft assessment order in the name of 'Wiley Subscription Services Inc. (now known as John Wiley & Sons Inc.). Accordingly, the fact that John Wiley & Sons

John Wiley & Sons, Inc., United States vs. DCIT, Int.Taxation, Circle 3(1)(1), New Delhi

The appeals are allowed

ITA 1872/DEL/2022[2018-19]Status: DisposedITAT Delhi20 Feb 2023AY 2018-19

Bench: Shri N. K. Billaiya & Shri Anubhav Sharma

For Appellant: Sh. Salil Kapoor & Vibhu Jain, AdvsFor Respondent: Sh. Sanjay Kumar Bharati, CIT DR

specifically directed in para 2.1 as follows:- 2.1 In regard to the above Ground, it is seen that the AO has passed the draft assessment order in the name of 'Wiley Subscription Services Inc. (now known as John Wiley & Sons Inc.). Accordingly, the fact that John Wiley & Sons

Quantum Clothing India Private Limited, Visakhapatnam vs. The Assistant Commissioner of Income Tax, Circle-5(1), Visakhapatnam

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

ITA 603/VIZ/2018[2014-15]Status: DisposedITAT Visakhapatnam16 Feb 2023AY 2014-15

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

For Appellant: Sri R. VijayaraghavanFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 115JSection 142(1)Section 143(1)Section 143(2)Section 143(3)Section 92CSection 92C(3)

determining the adjustment U/s. 92CA at Rs. 17,98,23,483/-. The Ld. AO considering the order of the Ld. TPO, passed a draft assessment order on 28/12/2017. The Ld. AO also made an addition of Rs. 32,04,997/- for the delay in payment of employees contribution of Provident ... Fund [PF] during the relevant assessment year 2014-15. Aggrieved by the draft assessment order, the assessee filed its objections before the Learned Dispute Resolution Panel, Bangaluru [DRP]. Before the Ld. DRP the assessee raised various objections particularly on the rejection of the TP Documentation and selection of comparables

Travelport Lp, Georgia Usa vs. DCIT, International Taxation Circle-3(1)(1), New Delhi

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

ITA 6503/DEL/2019[2011-12]Status: DisposedITAT Delhi09 Feb 2023AY 2011-12

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Shri Ravi Sharma, AdvFor Respondent: Shri Jitender Kumar – CIT-DR
Section 144Section 144C(13)Section 147Section 148Section 234ASection 234C

jurisdiction, bad in law and void ab initio. 2. That on the facts and in the circumstances of the case & in law, the draft assessment order dated December 03, 2018 passed by the Ld. AO under Section i44C(i) read with Sections ... initio. It is the say of the ld. counsel for the assessee that the Assessing Officer has grossly erred in framing a draft assessment order dated 03.12.2018 when the same was not at all required on the facts of the case. Therefore, the assessment order dated 21.06.2019 deserves

ACIT, New Delhi vs. M/S. Tirupati Buildings & Officers Pvt. Ltd., New Delhi

ITA 2405/DEL/2016[2010-11]Status: DisposedITAT Delhi09 Feb 2023AY 2010-11

Bench: Shri Anil Chaturvedi & Shri Chandra Mohan Gargassessment Year: 2010-11 The Acit, Central M/S. Tirupati Buildings & Circle-18, Jhandewalan, Offices Pvt. Ltd., New Delhi 110055 Vs. Plot No. 3, Dwarka City Centre Sector-10, Dwarka, New Delhi 110017 Pan Aacct7060J (Appellant) (Respondent) For Revenue : Shri Amaresh Singh, Cit Dr For Assessee : Shri Mahavir Singh, Advocate

For Appellant: Shri Mahavir Singh, AdvocateFor Respondent: Shri Amaresh Singh, CIT DR
Section 133(6)Section 250Section 4Section 68

which allowed relief on merit, is also supported on legal ground of non-application of mind by Addl. CIT while granting approval to draft assessment order u/s 153D of the Act. He submitted that this ground is purely legal in nature and goes to the root of the matter. Therefore ... urging the additional ground pertaining M/s. Tirupati Buildings & Offices Pvt. Ltd. Page 14 of 58 to the issue of approval of draft assessment order u/s 153D of the Act. He submitted that since, the assessee did not file any cross appeal or cross objection

Maruti Suzuki India Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal of the Revenue in ITA No

ITA 961/DEL/2015[2010-11]Status: DisposedITAT Delhi09 Feb 2023AY 2010-11

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2010-11] Maruti Suzuki India Ltd., Vs Dcit, Plot No.1, Nelson Mandela Road, Circle-16(1), Vasant Kunj, New Delhi-110070. New Delhi. Pan-Aaacm0829Q Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs Maruti Suzuki India Ltd., Circle-16(1), Plot No.1, Nelson Mandela Road, New Delhi. Vasant Kunj, New Delhi-110070. Pan-Aaacm0829Q Appellant Respondent Appellant By Shri Ajay Vohra, Sr.Adv., Shri Neeraj Jain, Adv. & Ms. Tejasvi Jain & Ms. Somya Jain, Ca Respondent By Shri G.C.Srivastava, Adv., Shri Kalrav Mehrotra, Adv. & Shri Mayank Patawari, Ca Date Of Hearing 11.11.2022 Date Of Pronouncement 09.02.2023

Section 143(3)Section 144CSection 144C(5)Section 43Section 43B

Dispute Resolution Panel (“DRP”) under section 144C(5) of the Act without judiciously and independently considering the factual and legal objections to the draft assessment order, is illegal and bad in law. 1.2. That the DRP erred on facts and in law in not interfering with the draft order passed ... Thereafter, the case was taken up for scrutiny assessment. Having taken into account, the transfer pricing adjustments a draft assessment order u/s 144C of the Act was passed on 29.03.2014 determining income at Rs. 4896,58,43,555/-. Aggrieved against it the assessee company filed its objections against the draft

DCIT, New Delhi vs. M/S. Maruti Suzuki India Ltd., New Delhi

In the result, the appeal of the Revenue in ITA No

ITA 1507/DEL/2015[2010-11]Status: DisposedITAT Delhi09 Feb 2023AY 2010-11

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2010-11] Maruti Suzuki India Ltd., Vs Dcit, Plot No.1, Nelson Mandela Road, Circle-16(1), Vasant Kunj, New Delhi-110070. New Delhi. Pan-Aaacm0829Q Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs Maruti Suzuki India Ltd., Circle-16(1), Plot No.1, Nelson Mandela Road, New Delhi. Vasant Kunj, New Delhi-110070. Pan-Aaacm0829Q Appellant Respondent Appellant By Shri Ajay Vohra, Sr.Adv., Shri Neeraj Jain, Adv. & Ms. Tejasvi Jain & Ms. Somya Jain, Ca Respondent By Shri G.C.Srivastava, Adv., Shri Kalrav Mehrotra, Adv. & Shri Mayank Patawari, Ca Date Of Hearing 11.11.2022 Date Of Pronouncement 09.02.2023

Section 143(3)Section 144CSection 144C(5)Section 43Section 43B

Dispute Resolution Panel (“DRP”) under section 144C(5) of the Act without judiciously and independently considering the factual and legal objections to the draft assessment order, is illegal and bad in law. 1.2. That the DRP erred on facts and in law in not interfering with the draft order passed ... Thereafter, the case was taken up for scrutiny assessment. Having taken into account, the transfer pricing adjustments a draft assessment order u/s 144C of the Act was passed on 29.03.2014 determining income at Rs. 4896,58,43,555/-. Aggrieved against it the assessee company filed its objections against the draft

Sh. Mdlr Hotels P. Ltd., New Delhi vs. DCIT, New Delhi

In the result, the captioned appeals by the Revenue are

ITA 3076/DEL/2016[2008-09]Status: DisposedITAT Delhi08 Feb 2023AY 2008-09

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

through a single order passed on 31-3-1997 without giving any reason whatsoever. As we have recorded elsewhere above, the draft assessment orders of the block period in all these cases were made on 31-3- 1997 and on the very same ... findings recorded by the Assessing Officer and setting-aside the assessment orders on the sole ground of defect in the approval to the draft assessment orders granted by the competent Approving Authority. Learned counsel for the Assessee, however, defended the order of the tribunal for the reasoning given therein. Considering

DCIT, C-11(1), New Delhi vs. Hero Motocorp Ltd., New Delhi

Appeal of the Revenue is dismissed

ITA 1982/DEL/2019[2014-15]Status: DisposedITAT Delhi03 Feb 2023AY 2014-15

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat

Section 14ASection 2(22)(e)Section 40Section 40a

case for the assessment year 2008-09. It would further be appreciated that similar disallowance made by the assessing officer in the draft assessment order for assessment years 2010-11 and 2011-12 on identical basis as adopted in the draft assessment order for the relevant assessment year, was deleted

Bibhudutta Panda, Bhubaneswar vs. Asst.CIT, Corporate Circle 1(2), Bhubaneswar

In the result, all appeals of the assessee stand allowed

ITA 81/CTK/2022[2012-13]Status: DisposedITAT Cuttack01 Feb 2023AY 2012-13

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri S.K.Agrawalla/S.K.Hota, ArsFor Respondent: Shri M.K.Gautam, CIT-DR
Section 142(1)Section 153ASection 153D

proceed with the assessment order without awaiting any further approval from him. The relevant portion of his approval reads as follows :- “The draft assessment orders in all the above noted assessees are approved accordingly as per statutory requirement u/s. 153D only in the light of the suggestions given above. Therefore ... book (Volume-1) filed by the ld. AR of the assessee. The Addl. CIT, Range-1 (Supervisory Office) has clearly mentioned therein that draft assessment orders in the case of M/s. Neelachal Carbo Metallics Pvt. Ltd. have been received late i.e. 25.03.2015 but there is no mention about other assesses

Bibhudutta Panda, Bhubaneswar vs. Asst.CIT Corporate Circle-1(2), Bhubaneswar

In the result, all appeals of the assessee stand allowed

ITA 80/CTK/2022[2011-12]Status: DisposedITAT Cuttack01 Feb 2023AY 2011-12

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri S.K.Agrawalla/S.K.Hota, ArsFor Respondent: Shri M.K.Gautam, CIT-DR
Section 142(1)Section 153ASection 153D

proceed with the assessment order without awaiting any further approval from him. The relevant portion of his approval reads as follows :- “The draft assessment orders in all the above noted assessees are approved accordingly as per statutory requirement u/s. 153D only in the light of the suggestions given above. Therefore ... book (Volume-1) filed by the ld. AR of the assessee. The Addl. CIT, Range-1 (Supervisory Office) has clearly mentioned therein that draft assessment orders in the case of M/s. Neelachal Carbo Metallics Pvt. Ltd. have been received late i.e. 25.03.2015 but there is no mention about other assesses

Bibhudutta Panda, Bhubaneswar vs. Asst.CIT, Corporate Circle-1(2), Bhubaneswar

In the result, all appeals of the assessee stand allowed

ITA 79/CTK/2022[2010-11]Status: DisposedITAT Cuttack01 Feb 2023AY 2010-11

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri S.K.Agrawalla/S.K.Hota, ArsFor Respondent: Shri M.K.Gautam, CIT-DR
Section 142(1)Section 153ASection 153D

proceed with the assessment order without awaiting any further approval from him. The relevant portion of his approval reads as follows :- “The draft assessment orders in all the above noted assessees are approved accordingly as per statutory requirement u/s. 153D only in the light of the suggestions given above. Therefore ... book (Volume-1) filed by the ld. AR of the assessee. The Addl. CIT, Range-1 (Supervisory Office) has clearly mentioned therein that draft assessment orders in the case of M/s. Neelachal Carbo Metallics Pvt. Ltd. have been received late i.e. 25.03.2015 but there is no mention about other assesses

Bibhudutta Panda, Bhubaneswar vs. Asst.CIT, Corporate Circle-1(2), Bhubaneswar

In the result, all appeals of the assessee stand allowed

ITA 78/CTK/2022[2009-10]Status: DisposedITAT Cuttack01 Feb 2023AY 2009-10

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri S.K.Agrawalla/S.K.Hota, ArsFor Respondent: Shri M.K.Gautam, CIT-DR
Section 142(1)Section 153ASection 153D

proceed with the assessment order without awaiting any further approval from him. The relevant portion of his approval reads as follows :- “The draft assessment orders in all the above noted assessees are approved accordingly as per statutory requirement u/s. 153D only in the light of the suggestions given above. Therefore ... book (Volume-1) filed by the ld. AR of the assessee. The Addl. CIT, Range-1 (Supervisory Office) has clearly mentioned therein that draft assessment orders in the case of M/s. Neelachal Carbo Metallics Pvt. Ltd. have been received late i.e. 25.03.2015 but there is no mention about other assesses