← 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

D.C.I.T Cir - 10(1), Kolkata vs. M/S Eureka Forbs Ltd, Kolkata

The appeal is dismissed

ITA 2037/KOL/2019[2015-16]Status: DisposedITAT Kolkata12 Jan 2026AY 2015-16

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 14ASection 250Section 92C

passed an Order u/s 92CA(3) of the Act on January 25, 2016. On receipt of the Ld. TPO's order, the Draft Assessment Order was passed on 10.03.2016 and was sent to the assessee. Vide letter dated 22nd March, 2016 the assessee stated that they were not filing ... application with the Dispute Resolution Panel against the Draft Assessment Order and would prefer an appeal with the Ld. CIT(A). Thereafter, a Final Assessment Order u/s 143(3) r.w.s. 144C of the Act was passed assessing the total income of the assessee at ₹52,72,64,911/-. Aggrieved with

D.C.I.T Cir - 10(1), Kolkata vs. M/S Eureka Forbs Ltd, Kolkata

The appeal is dismissed

ITA 1248/KOL/2019[2014-15]Status: DisposedITAT Kolkata12 Jan 2026AY 2014-15

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 14ASection 250Section 92C

passed an Order u/s 92CA(3) of the Act on January 25, 2016. On receipt of the Ld. TPO's order, the Draft Assessment Order was passed on 10.03.2016 and was sent to the assessee. Vide letter dated 22nd March, 2016 the assessee stated that they were not filing ... application with the Dispute Resolution Panel against the Draft Assessment Order and would prefer an appeal with the Ld. CIT(A). Thereafter, a Final Assessment Order u/s 143(3) r.w.s. 144C of the Act was passed assessing the total income of the assessee at ₹52,72,64,911/-. Aggrieved with

D.C.I.T Cir - 10(1), Kolkata vs. M/S Eureka Forbs Ltd, Kolkata

The appeal is dismissed

ITA 1247/KOL/2019[2013-14]Status: DisposedITAT Kolkata12 Jan 2026AY 2013-14

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 14ASection 250Section 92C

passed an Order u/s 92CA(3) of the Act on January 25, 2016. On receipt of the Ld. TPO's order, the Draft Assessment Order was passed on 10.03.2016 and was sent to the assessee. Vide letter dated 22nd March, 2016 the assessee stated that they were not filing ... application with the Dispute Resolution Panel against the Draft Assessment Order and would prefer an appeal with the Ld. CIT(A). Thereafter, a Final Assessment Order u/s 143(3) r.w.s. 144C of the Act was passed assessing the total income of the assessee at ₹52,72,64,911/-. Aggrieved with

D.C.I.T Cir - 10(1), Kolkata vs. M/S Eureka Forbs Ltd, Kolkata

The appeal is dismissed

ITA 1246/KOL/2019[2012-13]Status: DisposedITAT Kolkata12 Jan 2026AY 2012-13

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 14ASection 250Section 92C

passed an Order u/s 92CA(3) of the Act on January 25, 2016. On receipt of the Ld. TPO's order, the Draft Assessment Order was passed on 10.03.2016 and was sent to the assessee. Vide letter dated 22nd March, 2016 the assessee stated that they were not filing ... application with the Dispute Resolution Panel against the Draft Assessment Order and would prefer an appeal with the Ld. CIT(A). Thereafter, a Final Assessment Order u/s 143(3) r.w.s. 144C of the Act was passed assessing the total income of the assessee at ₹52,72,64,911/-. Aggrieved with

Mahathi Engineering Industries Private Limited, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

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

ITA 802/HYD/2025[2018-19]Status: DisposedITAT Hyderabad09 Jan 2026AY 2018-19

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 143(3)Section 263

आयकर अपीलीय न्यायाधिकरण में, हैदराबाद ‘बी’ बेंच, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad “B” Bench, Hyderabad श्री मंजूनाथ

Mohsin Himmati, Hyderabad vs. ADIT(Int Taxn)-1, Hyderabad

ITA 1768/HYD/2025[2023-24]Status: DisposedITAT Hyderabad09 Jan 2026AY 2023-24
For Appellant: Adv. R. Mohan KumarFor Respondent: Smt.U Mini Chandran, CIT(DR)
Section 139(1)Section 143(3)Section 144C(1)

Rs.2,31,12,000/- was treated as long-term capital gain by the Ld. AO in the hands of the assessee. Accordingly, a draft assessment order under section 144C(1) of the Act dated 20.02.2025 was passed by the Ld. AO determining the total income of the assessee at Rs.5

Nagineni Subbarathnamma, Rajampet vs. ITO., Ward-1, Kadapa

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

ITA 1326/HYD/2025[2013-14]Status: DisposedITAT Hyderabad09 Jan 2026AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1326/Hyd/2025 Assessment Year 2013-2014 Nagineni The Income Tax Officer, Subbarathnamma, Ward-1, Kadapa. Vs. Rajampet. Kadapa Dt. Pin – 516 001. Andhra Pradesh. Pan Agkpn8371K (Appellant) (Respondent) िनधा""रती "ारा /Assessee By: Ca K Abhiroop Bhargav राज" व "ारा /Revenue By: Sri Sankar Pandi P. Sr. Ar सुनवाई की तारीख/Date Of Hearing: 07.01.2026 घोषणा की तारीख/Pronouncement: 09.01.2026 आदेश/Order

For Appellant: CA K Abhiroop BhargavFor Respondent: Sri Sankar Pandi P. Sr. AR
Section 139Section 144BSection 147Section 148Section 234ASection 234BSection 250Section 69

have erred in confirming the Assessment Order passed by the Ld. AO, which has been issued without providing the Appellant with a draft Assessment Order under Section 144B of the Act and therefore the Assessment Order u/s 147 as well as the Order u/s 250 of the Act are liable

Shri Deepak Devidas Sajnani, Uae vs. The Income Tax Officer Int. Tax Ward 4(2)(1), Mumbai

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

ITA 1761/MUM/2025[2015-16]Status: DisposedITAT Mumbai09 Jan 2026AY 2015-16

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailshri Deepak Devidas Sajnani, Shop No.1 & 2, Jaffer Ali Building, Juma Masjid Road, P.O. Box No.6125, Bur Dubai, Uae - 999999 ............... Appellant Pan : Bocps6337H V/S The Income Tax Officer (International ……………… Respondent Taxation), Ward – 4(2)(1), Mumbai - 400051

For Appellant: Shri Tarun Mittal (Virtually Present)For Respondent: Shri Krishna Kumar, Sr.DR
Section 144Section 144C(1)Section 144C(5)Section 147Section 148Section 148ASection 69

unexplained investment under section 69 of the Act and proposed to add the same to the total income of the assessee vide draft assessment order dated 28.03.2024 passed under section 144C(1) of the Act. 5. The learned DRP (“DRP”), vide its directions dated 24.12.2024 issued under section 144C ... section 69 of the Act. Since the assessee could not explain the nature and source of investment in immovable property, the AO, vide draft assessment order, proposed an addition of Rs. 2,55,91,725/- under section 69 of the Act. It is evident from the record that

Vodafone Mobile Services Ltd., Ahmedabad vs. DCIT, New Delhi

ITA 922/DEL/2017[2012-13]Status: DisposedITAT Mumbai09 Jan 2026AY 2012-13

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarvodafone Mobile Dcit Circle-26(2), C.R. Building, New Services Limited Delhi-110015 (Former Known As Vs. Vodafone West Limited). Vodafone House, B-Wing, 4Th Floor, Corporate Road, Prahladnagar, Ahmedabad-380015 Pan/Gir No. Aaacs4457Q (Applicant) (Respondent) Assessee By Shri Ketan Ved & Shri Ninad Patade, Ld. Ars Revenue By Shri Pankaj Kumar, Ld. Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 09 .01.2026

Section 143(1)Section 143(3)Section 144CSection 144C(2)Section 144C(4)Section 144C(5)Section 14ASection 37(1)Section 92C

passed an order under section 92CA(3) of the Act dated 19.01.2016, proposing certain transfer pricing adjustments. Thereafter, the Assessing Officer passed a draft assessment order under section 144C read with section 143(3) of the Act in March 2016, incorporating the proposed transfer pricing adjustments as well as certain ... other disallowances. 3 Vodafone Mobile Services Limited 3. Aggrieved by the draft assessment order, the assessee filed objections before the DRP under section 144C(2) of the Act.The DRP, after considering the objections of the assessee, issued its directions under section 144C(5) of the Act vide order dated

Jatin Arora, Delhi vs. ACIT, Central Circle

ITA 5410/DEL/2025[2019-20]Status: DisposedITAT Delhi09 Jan 2026AY 2019-20

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Sh. Pranshu Singhal, CAFor Respondent: Ms. Monika Singh, CIT(DR)
Section 132Section 153C

approval taken by the Assessing Officer for passing the assessment order is not proper. He further submitted that the assessing Officer sent the draft assessment order for approval for all seven years through a single letter. The approval was granted by the Addl. Commissioner of Income Tax for all seven ... case of the assessee. The said order also fail to make any mention of the fact that the draft assessment orders were perused at all, much less perusal of the same with an independent application of mind. Also, we cannot lose sight of the fact that in the instant case

Jatin Arora, Delhi vs. ACIT, Delhi

ITA 5409/DEL/2025[2018-19]Status: DisposedITAT Delhi09 Jan 2026AY 2018-19

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Sh. Pranshu Singhal, CAFor Respondent: Ms. Monika Singh, CIT(DR)
Section 132Section 153C

approval taken by the Assessing Officer for passing the assessment order is not proper. He further submitted that the assessing Officer sent the draft assessment order for approval for all seven years through a single letter. The approval was granted by the Addl. Commissioner of Income Tax for all seven ... case of the assessee. The said order also fail to make any mention of the fact that the draft assessment orders were perused at all, much less perusal of the same with an independent application of mind. Also, we cannot lose sight of the fact that in the instant case

Jatin Arora, Delhi vs. ACIT, Delhi

ITA 5408/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Jan 2026AY 2017-18

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Sh. Pranshu Singhal, CAFor Respondent: Ms. Monika Singh, CIT(DR)
Section 132Section 153C

approval taken by the Assessing Officer for passing the assessment order is not proper. He further submitted that the assessing Officer sent the draft assessment order for approval for all seven years through a single letter. The approval was granted by the Addl. Commissioner of Income Tax for all seven ... case of the assessee. The said order also fail to make any mention of the fact that the draft assessment orders were perused at all, much less perusal of the same with an independent application of mind. Also, we cannot lose sight of the fact that in the instant case

Assistant Commissioner of Income Tax, Central Circle-25, New Delhi, Delhi vs. Avtar Singh Kochar, Haryana

ITA 4438/DEL/2025[2019-20]Status: DisposedITAT Delhi09 Jan 2026AY 2019-20

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. MayankPatawari, AdvFor Respondent: Sh. AlashOjha, Adv
Section 143(3)Section 153D

letter F. Nó. DCIT/CC-25/2021-22/175 dated 12.07.2021 on the above Approval is hereby accorded u/s 153D of the Income Tax Act, 1961 to the draft assessment order as amended in the following case, on the basis of the detailed discussion with you time to time, information available on record, facts mentioned ... certified to the undersigned that all information available in AIR/CIB/from other Law Enforcement Agencies have been properly scrutinized by you before finalizing the draft assessment order. Please ensure that penalty is levied under proper section of the Income Tax Act, 1961. 4. Wherever the reply of the assessee is reproduced

Prahlad Singh, Sonepat vs. PCIT, Rohtak, Sonepat

In the result, the appeal of the assessee is allowed in the above very

ITA 3563/DEL/2025[2020-21]Status: DisposedITAT Delhi09 Jan 2026AY 2020-21

Bench: Shri Mahavir Singh & Shri Amitabh Shuklaprahlad Singh, Vs. Pcit, Rohtak 1455/31, Gali No. 2, Ward No. 31, Aayakar Bhawan Pragati Nagar, Opp. Mansarovar Sonepat, Haryana-131001 Park, Rohtak (Pan: Crhps8742R) Haryana-124001 (Appellant) (Respondent) Assessee By : S/Shri Rahul Agarwal & Rajesh K. Agarwal, Advocates Revenue By : Shri Jitender Singh, Cit(Dr)

For Appellant: S/Shri Rahul Agarwal & Rajesh K. Agarwal, AdvocatesFor Respondent: Shri Jitender Singh, CIT(DR)
Section 115BSection 139(1)Section 143(3)Section 144Section 144BSection 263Section 69A

supporting documentary evidences which substantiate holding of land and earning of agricultural income. Subsequently, again the AO issued show cause notice enclosing therewith draft assessment order requesting the assessee to show cause as to why assessment in his case should not be finalized as per draft assessment order treating

Avtar Singh Kochar, Rohtak vs. DCIT, Central Circle-25, Delhi

ITA 2909/DEL/2025[2019-20]Status: DisposedITAT Delhi09 Jan 2026AY 2019-20

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. MayankPatawari, AdvFor Respondent: Sh. AlashOjha, Adv
Section 143(3)Section 153D

letter F. Nó. DCIT/CC-25/2021-22/175 dated 12.07.2021 on the above Approval is hereby accorded u/s 153D of the Income Tax Act, 1961 to the draft assessment order as amended in the following case, on the basis of the detailed discussion with you time to time, information available on record, facts mentioned ... certified to the undersigned that all information available in AIR/CIB/from other Law Enforcement Agencies have been properly scrutinized by you before finalizing the draft assessment order. Please ensure that penalty is levied under proper section of the Income Tax Act, 1961. 4. Wherever the reply of the assessee is reproduced

Fcs Computer Systems S Pte Ltd, India vs. Assistant Commissioner of Income Tax, Circle Int Tax 1(3)(1), India

In the result, the appeal of the Assessee is allowed

ITA 1034/DEL/2025[2022-23]Status: DisposedITAT Delhi09 Jan 2026AY 2022-23

Bench: Shri M. Balaganesh & Shri Vimal Kumarfcs Computer Systems S Pte Ltd, Vs. Acit, Office No. 07, 5Th Floor, A-40, I- International Taxation- Thum Tower-C, Sector-62, Up 1(3)(1), Delhi (Appellant) (Respondent) Pan: Aaacf7319J Assessee By : Shri Ashwani Taneja, Adv Shri Divyansh Dubery, Adv Shri Shivam Kukreja, Adv Ms. Ria Toyal, Adv Revenue By: Ms. Ekta Jain, Cit Dr Date Of Hearing 04/12/2025 Date Of Pronouncement 09/01/2026

For Appellant: Shri Ashwani Taneja, AdvFor Respondent: Ms. Ekta Jain, CIT DR
Section 143(3)Section 144C

India. The Learned AO, without considering the fact that the expenditure is attributable to the business of the branch in India, issued a draft assessment order under Section 144C(1) of the Act on 24- 03-2024 by disallowing the following expenses:- a) Cost of goods sold – software product ... were recharged without markup. 7. The Assessee filed objections before Learned Dispute Resolution Panel (DRP) against the proposed disallowance of expense in the draft assessment order referred to Supra. The Learned DRP issued directions under section 144C(5) of the Act to the Learned AO directing that if the present

Alok Kumar Rungta, Lucknow vs. NFAC, Delhi

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

ITA 598/LKW/2025[2014-15]Status: DisposedITAT Lucknow08 Jan 2026AY 2014-15

Bench: Shri Kul Bharatassessment Year: 2014-15 Alok Kumar Rungta V. National Faceless Appeal B-40 Flat No.34 Manoram Centre Apartment Aliganj, Lucknow- Delhi. 226024. Pan:Ajqpr0755G (Appellant) (Respondent) Appellant By: Shri Vijay Prakash Agarwal, Advocate Shri Akshay Agarwal, Advocate Respondent By: Shri R. R. N. Shukla, Addl Cit(Dr) Date Of Hearing: 28 10 2025 Date Of Pronouncement: 08 01 2026 O R D E R

For Appellant: Shri Vijay Prakash Agarwal, AdvocateFor Respondent: Shri R. R. N. Shukla, Addl CIT(DR)
Section 1Section 143(3)Section 147Section 148Section 150(1)

assessment, namely, unsecured loans amounting to Rs.14,08,400/- and commission income of Rs.1,16,417/-. Thereafter, the AO, after issuing a draft assessment order, passed the impugned assessment order, thereby repeating the very same additions which were originally made in the assessment order passed

Shriram Finance Ltd., Chennai vs. PCIT, Chennai

ITA 2043/CHNY/2025[2022-23]Status: DisposedITAT Chennai08 Jan 2026AY 2022-23

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2043/Chny/2025 िनधा"रण वष"/Assessment Year: 2022-23 Shriram Finance Limited, Vs. The Principal Commissioner Of [Since Shriram City Union Finance Income Tax – 3, Limited Amalgamated With Shriram Chennai. Transport Finance Co. Limited & Presently Known As Shriram Finance Limited], Sri Towers, Plot No. 14A, South Phase, Industrial Estate, Guindy, Chennai 600 032. [Pan:Aaacs7018R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 15.10.2025 घोषणा की तारीख /Date Of Pronouncement : 08.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.05.2025 Passed By The Ld. Principal Commissioner Of Income Tax – 3, Chennai For The Assessment Year 2022-23 Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri C.N. Bipin, CIT
Section 143(3)Section 234DSection 263Section 36(1)(vii)Section 36(1)(viia)Section 4

issued to the amalgamating company which was followed by notice under Section 142(1) of the IT Act, 1961. Thereafter, a draft assessment order was passed in the name of SPIL (amalgamated with MSIL) and final assessment order was passed in the name of SPIL (amalgamated with MSIL) making certain

Angalakshmi Spinning Mill, Coimbatore vs. DCIT, Non Corporate Circle-4, Coimbatore

The Appeal is dismissed qua the issue of the extent of deduction under Section 80-IA of the Act

ITA 2260/CHNY/2025[2018-19]Status: DisposedITAT Chennai07 Jan 2026AY 2018-19

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2260/Chny/2025 िनधा#रण वष# /Assessment Year: 2018-19

For Appellant: Mr. A. Arjun Raj, C.A (virtual)For Respondent: Ms. Latchana, JCIT
Section 143(2)Section 153(1)Section 234ASection 250Section 801ASection 80I

assessee claimed the interest income as business income and claimed deduction u/s 801A is factually incorrect and against his own finding in the draft assessment order and CIT(A) is erred in upholding the same. 3. The levy of interest of Rs. 9,320/- u.s 234A

The Uk Trade Desk Ltd, Mumbai vs. ACIT (Int.Tax)-4(3)(1), Mumbai

In the result, various sub grounds of ground no

ITA 2038/MUM/2025[2022-23]Status: DisposedITAT Mumbai07 Jan 2026AY 2022-23

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) The Uk Trade Desk Ltd. Acit (International Taxation-4(3)(1), 10Th Floor, 1 Bartholomew Close, Vs Mumbai, 6Th Floor, Kautilya Bhavan, Bkc, London, United Kingdom. [Pan No. Aahct6320Q] Bandra East, Mumbai – 400051. Appellant / Assessee Respondent / Revenue

Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 254(1)Section 9(1)(i)

profit as per Rule 10 of Income Tax Rules. The assessing officer thereby made the addition of Rs. 58,93,470/- in the draft assessment order on the basis of following calculation: Particulars Amount (Rs.) Total Business Revenue from Indian operations ... from India (A) Business profits from India assumed at 20% of (A) 58,93,471/- Total income 58,93,470/- 3. Copy of draft assessment order was served upon the assessee. The assessee exercised its option to file objection before DRP. The DRP in its direction dated 24.12.2024 upheld