← All Phrases

“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

Dy Commissioner of Income Tax (Int Tax)- 3(2)(1), Mumbai vs. Marriott International Inc, Mumbai

Appeal are dismissed

ITA 34/MUM/2026[2010-11]Status: DisposedITAT Mumbai06 Mar 2026AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Krishna KumarFor Respondent: Shri Pratik Poddar, Shri Karan Jain
Section 144CSection 271(1)(c)

made by rival sides the fact emerges that in the second round, the AO passed final assessment order dated 29/12/2016 without passing the draft assessment order. 10. Provisions of section 144C of the Act lays down the procedure to be followed under special mechanism. The AO is first required ... pass draft assessment order u/s 144C (1) of the Act. On receipt of the draft assessment order, the eligible assessee within 30 days either accepts the variations or may file objections, against such variations before the DRP. If no objections are filed against the draft assessment order, the AO shall

Ritesh Madnani, Raipur vs. ACIT, Central Circle-1, Raipur

The appeals of the assessee are allowed

ITA 61/RPR/2026[2018-19]Status: HeardITAT Raipur05 Mar 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.58, 59, 60 & 61/Rpr/2026 "नधा"रण वष" /Assessment Years : 2015-16, 2016-17, 2017-18 & 2018-19 Shri Ritesh Madnani Psm-4, Nacharani Bhawan, Jeevan Petrol Pump, Panchsheel Nagar, Raipur-492 001 (C.G.) Pan: Adwpm2804K

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 153D

raised by the 13 Shri Ritesh Madnani Vs. ACIT, CC-1, Raipur (C.G.) ITA Nos. 58, 59, 60 & 61/RPR/2026 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 ... leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment order under Section 153A." [Emphasis supplied] 12. It is observed that the Court in the case of Sapna Gupta (supra

Ritesh Madnani, Raipur vs. ACIT, Central Circle-1, Raipur

The appeals of the assessee are allowed

ITA 60/RPR/2026[2017-18]Status: HeardITAT Raipur05 Mar 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.58, 59, 60 & 61/Rpr/2026 "नधा"रण वष" /Assessment Years : 2015-16, 2016-17, 2017-18 & 2018-19 Shri Ritesh Madnani Psm-4, Nacharani Bhawan, Jeevan Petrol Pump, Panchsheel Nagar, Raipur-492 001 (C.G.) Pan: Adwpm2804K

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 153D

raised by the 13 Shri Ritesh Madnani Vs. ACIT, CC-1, Raipur (C.G.) ITA Nos. 58, 59, 60 & 61/RPR/2026 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 ... leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment order under Section 153A." [Emphasis supplied] 12. It is observed that the Court in the case of Sapna Gupta (supra

Ritesh Madnani, Raipur vs. ACIT, Central Circle-1, Raipur

The appeals of the assessee are allowed

ITA 59/RPR/2026[2016-17]Status: HeardITAT Raipur05 Mar 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.58, 59, 60 & 61/Rpr/2026 "नधा"रण वष" /Assessment Years : 2015-16, 2016-17, 2017-18 & 2018-19 Shri Ritesh Madnani Psm-4, Nacharani Bhawan, Jeevan Petrol Pump, Panchsheel Nagar, Raipur-492 001 (C.G.) Pan: Adwpm2804K

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 153D

raised by the 13 Shri Ritesh Madnani Vs. ACIT, CC-1, Raipur (C.G.) ITA Nos. 58, 59, 60 & 61/RPR/2026 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 ... leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment order under Section 153A." [Emphasis supplied] 12. It is observed that the Court in the case of Sapna Gupta (supra

Ritesh Madnani, Raipur vs. ACIT, Central Circle-1, Raipur

The appeals of the assessee are allowed

ITA 58/RPR/2026[2015-16]Status: HeardITAT Raipur05 Mar 2026AY 2015-16

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.58, 59, 60 & 61/Rpr/2026 "नधा"रण वष" /Assessment Years : 2015-16, 2016-17, 2017-18 & 2018-19 Shri Ritesh Madnani Psm-4, Nacharani Bhawan, Jeevan Petrol Pump, Panchsheel Nagar, Raipur-492 001 (C.G.) Pan: Adwpm2804K

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 153D

raised by the 13 Shri Ritesh Madnani Vs. ACIT, CC-1, Raipur (C.G.) ITA Nos. 58, 59, 60 & 61/RPR/2026 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 ... leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment order under Section 153A." [Emphasis supplied] 12. It is observed that the Court in the case of Sapna Gupta (supra

Amit Shantaram Bagade Mited, Mumbai vs. Income Tax Officer Int Taxation Ward 1(2), Mumbai

In the result, both the appeals filed by the assessee are partly allowed

ITA 832/MUM/2025[2019-20]Status: DisposedITAT Mumbai04 Mar 2026AY 2019-20

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Rohan Despande &For Respondent: Shri Krishna Kumar, Sr.DR
Section 132Section 142(1)Section 147Section 148Section 148ASection 151ASection 69

brought to tax u/s. 69 of the Act and the concluding findings of the AO are contained at para 11.6 of the draft assessment order passed u/s 144C(1) of the Act, dt. 29-03-2024, which read as under: “11.6 In view of the above facts and circumstances ... Penalty proceeding u/s 271AAC is separately initiated for addition made u/s 69 of the Act.” 5. Against the draft assessment order passed u/s. 144C(1) of the Act, dt. 29-03-2024, the assessee filed objections before the ld. Ld. DRP, which was disposed-off by the DRP vide

Amit Shantaram Bagade, Thane vs. ITO (Int Tax) Ward-1(2)(1), Mumbai

In the result, both the appeals filed by the assessee are partly allowed

ITA 6286/MUM/2025[2020-21]Status: DisposedITAT Mumbai04 Mar 2026AY 2020-21

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Rohan Despande &For Respondent: Shri Krishna Kumar, Sr.DR
Section 132Section 142(1)Section 147Section 148Section 148ASection 151ASection 69

brought to tax u/s. 69 of the Act and the concluding findings of the AO are contained at para 11.6 of the draft assessment order passed u/s 144C(1) of the Act, dt. 29-03-2024, which read as under: “11.6 In view of the above facts and circumstances ... Penalty proceeding u/s 271AAC is separately initiated for addition made u/s 69 of the Act.” 5. Against the draft assessment order passed u/s. 144C(1) of the Act, dt. 29-03-2024, the assessee filed objections before the ld. Ld. DRP, which was disposed-off by the DRP vide

Sridharan Shanmugam, Salem vs. ITO, International Taxation Ward, Coimbatore

In the result the appeal of the assessee is allowed

ITA 544/CHNY/2025[2022-23]Status: DisposedITAT Chennai03 Mar 2026AY 2022-23

Bench: Shri S.S.Viswanethra Ravi & Shri S.R.Raghunatha

For Appellant: Shri. P.M.Kathir, AdvocateFor Respondent: Ms. C.Vatchala, CIT
Section 143(3)Section 144(7)Section 144C(1)Section 144C(5)Section 69Section 69A

u/s.69A of the Act, apart from the source for investment of Rs.1.23 Crores in immovable property u/s.69 of the Act by issuing a draft assessment order u/s.144C(1) of the Act dated 17.06.2023. The assessee filed an objection against the draft assessment order of the AO, before

Comer Industries India Private Limited, Bangalore vs. DCIT, Circle 2(2)(1), Bangalore

In the result, the appeal by the assessee is dismissed

ITA 1228/BANG/2025[2017-18]Status: DisposedITAT Bangalore27 Feb 2026AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Balasubramanyam, CAFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT), Bengaluru
Section 139(1)Section 234CSection 263Section 36(1)(va)

Karnataka)/[2020] 268 Taxman 150 (Karnataka)/[2019] 419 ITR 391 (Karnataka)[27-09-2019] has held that "18. It is undisputed that Draft Assessment Order was notified by the AO in view of the fact that assessee's business involved International Money Transaction. Petitioner/assessee was entitled to have an opportunity ... look into Draft Assessment Order. He had option either to accept or to submit objections on variations. If objections were filed, in such an event, the AO is required to forward Draft Assessment Order and objections raised by the petitioner – assessee before the DRP to examine the objections raised

Shree Nath Kripa Foods Private Limited, Riico Industrial Area, Nokha vs. Income Tax Officer, ITO, Ward, Nokha

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

ITA 198/JODH/2024[2016-17]Status: DisposedITAT Jodhpur26 Feb 2026AY 2016-17

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Bleshree Nath Kripa Foods Pvt. Ltd. Income Tax Officer, Ito, Ward F-41 & F-42, Riico Industrial Bikaner Area, Nokha, Bikaner - 334803 Pan No. Aamcs 9124 Q Assessee By Shri Amit Kothari, Ca (Physical) Revenue By Shri Lalit Kumar Bishnoi, Addl. Cit-Dr (Virtual) Date Of Hearing 29.01.2026. Date Of Pronouncement 26.02.2026. Order Dr. Mitha Lal Meena, A.M.: This Appeal Is Filed By Assessee Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter Referred To As Nfac/ Cit(A)] Dated 30.01.2024 With Respect To Assessment Year 2016-17 Challenging Therein The Order Passed By The Ld. Cit(A) Ex-Parte In Violation Of Principles Of Natural Justice.

Section 143(3)Section 144Section 144cSection 92CSection 92E

specified under section 92E. 3. Under the facts and circumstances of the case the Ld. AO has grossly erred by not passing Draft assessment order under section 144c1 before making final assessment order under section 143(3) of the I.T. Act as the same contains an addition ... regarding adjustment in ALP. Order passed under section 143(3) on 28.12.2019 by Assessing Officer without prior passing of draft assessment order under section 144(c)(1) of the Act is totally illegal, unconstitutional, unjudicious, Arbitrary and void because the same has been passed violating the provision of section

Gs & Sd Associates, Chennai vs. ITO, Ncw-8(2), Chennai

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

ITA 2767/CHNY/2025[2017-18]Status: DisposedITAT Chennai26 Feb 2026AY 2017-18

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2767/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Gs & Sd Associates, Vs. The Income Tax Officer, No. 03, Vania Street, Kundrathur, Non Corporate Ward 8(2), Chennai 600 069. Chennai. [Pan:Aaqfg8838C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sridhar, Ca ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 08.01.2026 घोषणा की तारीख /Date Of Pronouncement 26.02.2026 : आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 22.08.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. The Assessee Raised 6 Grounds Amongst Which The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Addition Made By The Assessing Officer Under Section 68 Of The Income Tax Act , 1961 [“Act” In Short].

For Appellant: Shri Y. Sridhar, CAFor Respondent: Ms. R. Anita, Addl. CIT
Section 142(1)Section 143(2)Section 147Section 148Section 269SSection 68

assessee to provide source of ₹.7,00,00,000/-, which has advanced Shri Sambandam Dhanasekaran during the period from 01.09.2016 to 29.10.2016. A draft assessment order cum show-cause notice issued to the assessee and the assessee filed reply, which is evident at para 1 to 2.2 of the assessment

Owens Corning (Singapore) Pte Ltd, Mumbai vs. The DCIT (Int Tax) Circle-3(2)(2), Mumbai

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

ITA 5161/MUM/2025[2023-24]Status: DisposedITAT Mumbai26 Feb 2026AY 2023-24

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2023-24 Owens Corning (Singapore) Deputy Commissioner Of Pte Ltd., Income Tax (International Tax), C/O. Owens Corning (India) Vs. Circle-3(2)(2), Pvt. Limited, 6Th Floor, 7Th Floor, Alpha Building, Kautilya Bhavan, Hiranandani Gardens, Bandra Kurla Complex, Powai, Mumbai-400051. Maharashtra-400076. Pan : Aabco5666L (Appellant) (Respondent) For Assessee : Shri Sandeep Bhalla For Revenue : Shri Krishna Kumar, Sr.Dr Date Of Hearing : 02-12-2025 Date Of Pronouncement : 26-02-2026 O R D E R Per Vikram Singh Yadav, A.M : The Assessee Has Filed The Present Appeal Against The Final Assessment Order Dated 10-07-2025, Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 („The Act‟), Pursuant To The Directions Issued By The Learned Dispute Resolution Panel-2, Mumbai, ("Ld.Drp"), Pertaining To Assessment Year (Ay) 2023-24, Wherein The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Sandeep BhallaFor Respondent: Shri Krishna Kumar, Sr.DR
Section 115ASection 142(1)Section 143(2)Section 143(3)Section 234Section 234BSection 9(1)(vii)Section 90(2)

DTAA as no Royalty referred in Article 12(3) of the India Singapore DTAA was received by the assessee. 4. The AO, vide draft assessment order dated 17-03-2025, passed u/s. 144C(1) of the Act, disagreed with the submissions of the assessee and after noting no material change

Mamta Construction Co, Mehsana vs. Deputy Commissioner of Income Tax, Gandhinagar

In the result, the appeal of the assessee is allowed

ITA 1530/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalmamta Construction Co., Deputy Commissioner Vs. 20, Madhuvan Complex, Of Income-Tax, Nr. Icici Bank, State Highway, Gandhinagar Mehsana-384 002 [Pan :Aaifm 6254 A] (Appellant) .. (Respondent) Appellant By : Shri Hasmukh V. Doshi, Ca Respondent By: Shri Kamal Deep Singh, Sr. Dr Date Of Hearing 10.12.2025 Date Of Pronouncement 25.02.2026

For Appellant: Shri Hasmukh V. Doshi, CAFor Respondent: Shri Kamal Deep Singh, Sr. DR
Section 142(1)Section 250

facts in confirming the assessment order made abruptly without considering the reply and evidences attached with the reply in response to draft assessment order.” 3. The facts of the case are that the assessee is a partnership firm engaged in the business of civil contracting, including supply of pipelines ... same to the returned income. 3.2 The assessee submitted a detailed reply along with documentary evidences on 10.04.2021 in response to the draft assessment order, disputing the allegation of double debit. According to the assessee, the said reply was neither examined nor dealt with by the Assessing Officer

Samiuddin Aslam, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, all the 4 appeals filed by the assessee are allowed

ITA 1225/HYD/2025[2019-20]Status: DisposedITAT Hyderabad25 Feb 2026AY 2019-20

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1222 To 1225/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Vs. Asstt. Commissioner Of Hyderabad Income Tax, Central Circle 2(4) Hyderabad Pan: Ckvpa7727F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 22/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 115BSection 132Section 144C(5)Section 153CSection 69Section 69A

section 69 of the I.T. Act, 1961 as unexplained investment and brought to tax under section 115BBE of the Act and issued a draft assessment order dated 28/03/2024. 5. Aggrieved by the draft assessment order, the assessee has filed objections before the DRP-1, Bengaluru and challenged the adjustments proposed ... with the said provision. As per the provision of section 144C, in case of an eligible assessee, the Assessing Officer shall pass a draft assessment order and served on the assessee, if he propose to make any variation in his total income. The assessee, after receipt of draft assessment order

Samiuddin Aslam, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, all the 4 appeals filed by the assessee are allowed

ITA 1224/HYD/2025[2018-19]Status: DisposedITAT Hyderabad25 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1222 To 1225/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Vs. Asstt. Commissioner Of Hyderabad Income Tax, Central Circle 2(4) Hyderabad Pan: Ckvpa7727F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 22/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 115BSection 132Section 144C(5)Section 153CSection 69Section 69A

section 69 of the I.T. Act, 1961 as unexplained investment and brought to tax under section 115BBE of the Act and issued a draft assessment order dated 28/03/2024. 5. Aggrieved by the draft assessment order, the assessee has filed objections before the DRP-1, Bengaluru and challenged the adjustments proposed ... with the said provision. As per the provision of section 144C, in case of an eligible assessee, the Assessing Officer shall pass a draft assessment order and served on the assessee, if he propose to make any variation in his total income. The assessee, after receipt of draft assessment order

Samiuddin Aslam, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

ITA 1223/HYD/2025[2017-18]Status: DisposedITAT Hyderabad25 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.आ.अपी.सं / Ita Nos.1222 To 1225/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Hyderabad Pan: Ckvpa7727F (Appellant) Vs. Asstt. Commissioner Of Income Tax, Central Circle 2(4) Hyderabad (Respondent) निर्धारिती द्वारा / Assessee By: राजस्व द्वारा / Revenue By: Shri P. Murali Mohan Rao, Ca Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 22/01/2026 घोषणा की तारीख / Pronouncement: 25/02/2026 Per. Manjunatha, G. A.M. आदेश/Order These Four Appeals Filed By The Assessee Are Directed Against The Separate Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Respondent: Shri P. Murali Mohan Rao, CA
Section 132Section 144C(13)Section 148Section 153BSection 153CSection 69

with Central Circle-2(4). Therefore the Draft order passed by Ld. Central Circle 2(4) Hyderabad without assuming jurisdiction has passed draft assessment order on 28.03.2024 Technical ground 7 The Ld. AO made a huge addition of Rs. 4,26,80,000/- on the basis of loose sheets which ... section 69 of the I.T. Act, 1961 as unexplained investment and brought to tax under section 115BBE of the Act and issued a draft assessment order dated 28/03/2024. 5. Aggrieved by the draft assessment order, the assessee has filed objections before the DRP-1, Bengaluru and challenged the adjustments proposed

Samiuddin Aslam, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, all the 4 appeals filed by the assessee are allowed

ITA 1222/HYD/2025[2016-17]Status: DisposedITAT Hyderabad25 Feb 2026AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1222 To 1225/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Vs. Asstt. Commissioner Of Hyderabad Income Tax, Central Circle 2(4) Hyderabad Pan: Ckvpa7727F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 22/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 115BSection 132Section 144C(5)Section 153CSection 69Section 69A

section 69 of the I.T. Act, 1961 as unexplained investment and brought to tax under section 115BBE of the Act and issued a draft assessment order dated 28/03/2024. 5. Aggrieved by the draft assessment order, the assessee has filed objections before the DRP-1, Bengaluru and challenged the adjustments proposed ... with the said provision. As per the provision of section 144C, in case of an eligible assessee, the Assessing Officer shall pass a draft assessment order and served on the assessee, if he propose to make any variation in his total income. The assessee, after receipt of draft assessment order

ITO, W-1(3), Vaishali, Hajipur vs. Shiv Sharan Singh, Hajipur

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

ITA 524/PAT/2025[2014]Status: DisposedITAT Patna24 Feb 2026

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 147Section 148Section 250Section 251(1)(a)Section 69A

issued on 28.03.2021. The assessment order was passed after making the addition of ₹2,05,73,999/- while in the draft assessment order dated 12.03.2022 the addition proposed was for ₹1,04,04,266/-. Accordingly, the total income was assessed at ₹2,06,37,721/-. Aggrieved with the assessment order

ACIT, Circle-1(1)(1), Vadodara vs. Farmson Pharmaceutical Gujarat Private Limited, Vadodara

In the result, the appeal of the Revenue is dismissed

ITA 1835/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad23 Feb 2026AY 2015-16

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2015-16

For Appellant: Ms. Amrin Pathan, A.RFor Respondent: Shri Sher Singh, CIT-D.R
Section 115JSection 144(1)Section 37Section 92BSection 92CSection 92E

thereby making total adjustment of Rs. 8,93,76,234/- on account of purchase of parecetamoal. The A.O. passed draft assessment order u/s. 144(1) on 26-11-2018. On the basis of the findings of the draft assessment order, the A.O. observed that during the assessment proceedings, details

Goldman Sachs Services Private Limited, Bangalore vs. DCIT, Circle 3(1)(1), Bangalore

ITA 2525/BANG/2024[AY 2021-22]Status: DisposedITAT Bangalore23 Feb 2026

Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhur AgarwalFor Respondent: Dr. Divya K. J
Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 234ASection 270ASection 92C

Borrowings (ECB) and interest on delayed receivable amounting to INR.75,39,13,371/- and INR.29,837/-, respectively. 4. The Assessing Officer passed a Draft Assessment Order, dated 20/12/2023, under the provisions of section 143(3) read with section 144C read with section 144B of the Act incorporating the aggregate Transfer