“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

Avl Technical Centre Pvt. Ltd., New Delhi vs. DCIT, Circle-3(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 7705/DEL/2019[2008-09]Status: DisposedITAT Delhi11 Dec 2025AY 2008-09

Bench: Ms. Madhumita Roy & Mrs. Renu Jauhriasstt. Year: 2008-09 Avl Technical Private Limited, Vs Dcit Csc, C-9, Vasant Kunj, Central Circle-3(2) New Delhi-70 New Delhi (Appellant) (Respondent) Pan No. Aadca1470C

For Appellant: Shri Vishal Kalra, Adv. &For Respondent: Shri S.K. Jhadav, CIT( DR)

Section 133(6)Section 143(3)Section 144CSection 14ASection 254Section 92C

order was issued by the Ld. AO, as mandated under sub- section 1 of Section 44C. He has argued that issuance of a draft assessment order is a condition precedent to passing a final order, in case a variation prejudicial to the Assessee is proposed to be made. In this ... Sumitomo Corporation [2024] 166 taxmann.com 55 wherein it has been held that it was mandatory for the AO to pass a draft assessment order u/s 144C during remand proceedings and that a final assessment order passed without passing draft assessment order as mandated u/s144C of the Act is not tenable

Adp Private Limited, Hyderabad, Telangana vs. DCIT., Circle 1(1), Hyderabad, Telangana

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 332/HYD/2025[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 195(2)Section 40

period of 60 days, vide order dated 30.01.2024 passed under Section 92CA(3) of the Act. 4. Thereafter, the A.O. has passed the draft assessment order under Section 144C(1) of the Income-tax Act, 1961 on 30.03.2024, determining the total income ... Issued the notices. If the contention of the appellants/revenue was to hold some water, they must have passed the draft assessment order immediately on receipt of the order from the Tribunal, but instead, notice was issued by the DRP. In any case, it is a far cry for the revenue

Indeed India Operations Private Limited, Hyderabad vs. ACIT., Circle2(1), Hyderabad

In the result, appeal of the Assessee for the assessment year 2021-2022 is allowed

ITA 943/HYD/2024[AY 2020-21]Status: DisposedITAT Hyderabad10 Dec 2025

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.943 & 1359/Hyd/2024 Assessment Years 2020-2021 & 2021-2022 Indeed India Operations The Acit, Private Limited, Vs. Circle-2(1), Hyderabad – 500 081. Hyderabad. Telangana Pan Aadci5931J (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Mahima Goud, Advocate राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Mahima Goud, AdvocateFor Respondent: MS U Mini Chandran, CIT-DR

Section 143(3)Section 144BSection 144C(13)Section 153Section 92C(3)

sec.153. The learned DR has further submitted that as per the special provisions u/sec.144C, the assessee is having an option to accept the Draft Assessment Order and variations in the draft assessment or to object the same by filing objections before the DRP or to the Assessing Officer for going ... Issued the notices. If the contention of the appellants/revenue was to hold some water, they must have passed the draft assessment order immediately on receipt of the order from the Tribunal, but instead, notice was issued by the DRP. 17 ITA.Nos.943 and 1359/Hyd./2024 In any case

Calliduscloud (India) Private Limited, Hyderabad vs. DCIT., Circle- 1(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 1395/HYD/2024[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153

dated 29.10.2023 passed under Section 92CA(3) of the Act. 8 M/s. Callidus Cloud (India) Private Limited 4. Thereafter, the A.O. passed the draft assessment order under Section 144C(1) of the Income-tax Act, 1961 on 04.12.2023, determining the total income at Rs. 23,87,68,544/- by making ... Issued the notices. If the contention of the appellants/revenue was to hold some water, they must have passed the draft assessment order immediately on receipt of the order from the Tribunal, but instead, notice was issued by the DRP. In any case, it is a far cry for the revenue

Indeed India Operations Private Limited, Hyderabad vs. ACIT., Circle -(1), Hyderabad

ITA 1359/HYD/2024[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.943 & 1359/Hyd/2024

Section 143(3)Section 144BSection 144C(13)Section 153Section 92C(3)

learned DR has further submitted that as per the special provisions u/sec.144C, the assessee is having an option to accept the Draft Assessment Order and variations in the draft assessment or to object the same by filing objections before the DRP or to the Assessing Officer for going to challenge

Saxon Global India Private Limited, Hyderabad vs. ITO., Ward-3(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 1334/HYD/2024[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22

Section 144C(5)Section 92C

respect of the international transactions relating to provision of RPO services. The A.O. thereafter, passed the draft assessment order under Section 144C(1) on 29.12.2023, determining the total income at Rs. 2,19,83,955/-. 6. Aggrieved, the assessee filed its objections before the Dispute Resolution Panel against ... adjustment proposed in the draft assessment order. The Ld. DRP, after considering the submissions of the assessee and the material available on record, vide its 7 Saxon Global India Private Limited directions issued under Section 144C(5) of the Income-tax Act, 1961 on 19.09.2024, rejected all the objections raised

Parexel International (Irl) Limited, Ireland vs. ADIT (Int Taxn)-2, Hyderabad

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

ITA 447/HYD/2023[2020-21]Status: DisposedITAT Hyderabad10 Dec 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.447/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2020-21) Parexel International Vs. Additional Director Of (Irl) Limited, Ireland Income Tax Pan:Aaicp4417B Hyderabad (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Advocate Kanchun Kaushal राज" व "ारा/Revenue By:: Smt. U Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 19/11/2025 घोषणा की तारीख/Pronouncement: 10/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Parexel International (Irl) Limited, Ireland (“The Assessee”), Feeling Aggrieved By The Assessment Order Passed By The Learned Adit (Int. Taxation)-2, Hyderabad (“Ld. Ao”) Dated 07.07.2023 For The A.Y 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Advocate Kanchun KaushalFor Respondent: : Smt. U Mini Chandran

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 153(1)Section 153(4)Section 92C

assessees governed by section 153 of the Act. Under the special regime of section 144C of the Act, the assessee may accept the draft assessment order, object before the Ld. DRP, or file appeal before the Ld. CIT(A). Once the assessee chooses to file objections before ... There is also no dispute about the facts that the final assessment order was passed by the Ld. AO on 07.07.2023, the draft assessment order under section 143(3) read with section 144C(1) of the Act was passed on 30.09.2022, and the directions of Ld. DRP under section 144C

Interwrap Corp Private Limited (Successor of Owens Corning Industries (India) Private Limited), Mumbai vs. DCIT., Circle -5(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 496/HYD/2022[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

Bench: SHRI VIJAY PAL RAO, HON'BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

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

under Section 154 was passed on 19.08.2021, revising the purchase adjustment to Rs. 49,86,32,000/-. 6. Thereafter, the A.O. passed a draft assessment order under Section 143(3) r.w.s. 144C(1) of the Act on 21.09.2021, determining the total income at Rs. 69,97,35,729/-, by incorporating ... Issued the notices. If the contention of the appellants/revenue was to hold some water, they must have passed the draft assessment order immediately on receipt of the order from the Tribunal, but instead, notice was issued by the DRP. In any case, it is a far cry for the revenue

Dr. Reddys, Laboratories Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 491/HYD/2022[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

For Appellant: CA Padamchand KhinchaFor Respondent: MS. U Mini Chandran, CIT-DR

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

Dr. Reddys, Laboratories Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 490/HYD/2022[2017-18]Status: DisposedITAT Hyderabad10 Dec 2025AY 2017-18

For Appellant: CA Padamchand KhinchaFor Respondent: MS. U Mini Chandran, CIT-DR

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

Ntt Data Business Solutios Private Limited, Hyderabad vs. DCIT, Circle-5(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 489/HYD/2022[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.489/Hyd/2022 Assessment Year 2018-2019 Ntt Data Business The Dcit, Solutions Private Limited, Hyderabad. Circle-5(1), Vs. Pin -500081. Hyderabad. Pan Aadci1557Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: CA Aliasgar RampurawalaFor Respondent: MS U Mini Chandran, CIT-DR

Section 143(3)Section 144

further submitted that as per the special provisions u/sec.144C, the assessee is having an 13 ITA.No.489/Hyd./2022 option to accept the Draft Assessment Order and variations in the draft assessment or to object the same by filing objections before the DRP or to the Assessing Officer for going ... Issued the notices. If the contention of the appellants/revenue was to hold some water, they must have passed the draft assessment order immediately on receipt of the order from the Tribunal, but instead, notice was issued by the DRP. In any case, it is a far cry for the revenue

R.A.K Ceramics India Private Limited, Samalkot vs. DCIT Circle -3(1), Hyderabad

ITA 465/HYD/2022[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

Section 143(3)Section 144BSection 144C(5)

assessees governed by section 153 of the Act. Under the special regime of section 144C of the Act, the assessee may accept the draft assessment order, object before the Ld. DRP, or file appeal before the Ld. CIT(A). Once the assessee chooses to file objections before ... There is also no dispute about the facts that the final assessment order was passed by the Ld. AO on 20.07.2022, the draft assessment order under section 143(3) read with section 144C(1) of the Act was passed on 25.09.2021, and the directions of Ld. DRP under section 144C

Bombardier Inc., Quebec, Canada vs. Assistant Commissioner of Income Tax, Circle 1(1)(2), Delhi

In the result, the appeal of the Assessee are allowed

ITA 1022/DEL/2025[2018-19]Status: DisposedITAT Delhi10 Dec 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri Vimal Kumarbombardier Inc, Vs. Acit, 400, Dorval, Cote-Vertu, Circle-1(1)(2), Road West, Quebee Delhi Canada-H4S1Y9 (Appellant) (Respondent) Pan: Aaccb7177J Assessee By : Shri Sriram Seshadri, Cas Shri Varun Jain, Ca Shri Mohit Agarwal, Ca Ms. Amulya K. Ca Revenue By: Shri M. S. Nethrapal, Cit Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 10/12/2025

For Appellant: Shri Sriram Seshadri, CAsFor Respondent: Shri M. S. Nethrapal, CIT DR

Section 144C(5)Section 147Section 9(1)(vii)

under Article 12(4) of the India-Canada Treaty. The Learned AO in the draft assessment order proceeded to treat the amounts received from SpiceJet as fee for technical services and brought to tax a sum of Rs 41,64,62,765/- as income of the Assessee and completed ... draft assessment order. The Learned DRP issued directions under Section 144C(5) of the Act upholding the addition made by the Learned AO of treating the receipts as taxable both under the domestic law as well as under the Article 12(4) of the India- Bombardier Inc Canada Treaty, giving

Myntra Inc., United States of America vs. Assistant Commissioner of Income Tax Circle 2(2)(1), International Taxation, New Delhi

In the result, grounds of appeal no

ITA 3770/DEL/2023[2021-22]Status: DisposedITAT Delhi10 Dec 2025AY 2021-22

Bench: Shri Vikas Awasthy& Shri Naveen Chandraआअसं.3770/धिल्ली/2023(नि.व. 2021-22) Myntra Inc. 8201, 164Th Ave Ne, Suited 200, Redmond, Wa 98052, ...... अपीलार्थी/Appellant United States Of America, 98052 Pan Aalcm-3409-K बिाम Vs. Assistant Commissioner Of Income Tax, Circle International Tax 2(2)(1), Civic Centre, .....प्रनिवादी/Respondent Minto Road, New Delhi 110002 अपीलार्थी द्वारा/ Appellant By : Shri Sachit Jolly, Sr. Advocate With Ms. Rashi Khanna, Advocate प्रधिवािीद्वारा/Respondent By : Ms. Anjula Jain, Cit (Dr) & Shri Vikram Singh Sharma, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 12/09/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 10/12/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act,1961 (Hereinafter Referred To As ‘The Act’) Dated 16.10.2023, For Assessment Year 2021-22. 2. Shri Sachit Jolly, Sr. Advocate Appearing On Behalf Of The Assessee At The Outset Submitted That On Instructions From The Assessee/Appellant He Is Not 2 Pressing Ground No. 2 Of Appeal, Assailing Validity Of The Dispute Resolution Panel (Drp) Directions Sans Din. In Light Of The Statement Made By Ld. Counsel For The Assessee At Bar, Ground Of Appeal No. 2 Is Dismissed As Not Pressed.

For Appellant: Shri Sachit Jolly, Sr. Advocate with Ms. Rashi Khanna, AdvocateFor Respondent: Ms. Anjula Jain, CIT (DR) &

Section 143(3)Section 9(1)(vii)

DTAA ‘make available’ condition is required to be satisfied which is conspicuously missing in the instant case. Referring to para 6 of the Draft Assessment Order, the ld. Counsel contends that the AO has erred in recording that the assessee has made submissions that the assessee is assisting the Indian

Pico Deepali Overlays Consortium (by Deepali Designs Exhibits (P.) Ltd.), Delhi vs. DCIT, Central Circle-17, New Delhi

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

ITA 518/DEL/2022[2011-12]Status: DisposedITAT Delhi10 Dec 2025AY 2011-12

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2011-12 Pico Deepali Overlays Vs. Dcit, Central Circle-17, Consortium, C/O Mna & Co., Delhi Cas, Suite 444, Tower-B, Spazedge, Sector 47, Sohna Road, Gurgaon – 122 018 Pan :Aabap1880F (Appellant) (Respondent)

Section 144CSection 153ASection 92C

filed Miscellaneous Application No. 14886 of 2019 for clarification/modification order dated 30.07.2019. 2.6 In accordance to order of Income Tax Appellate Tribunal, draft assessment order treating M/s. Deepali Design & Exhibits Pvt. Ltd. as member of AOP in M/s. Pico Deepali Overlays Consortium as member of AOP in “M/s. Pico Deepali ... Overlays Consortium” proposing certain variations was passed on 31.03.2021 and sent to the Ld. AO. 2.7 Against draft assessment order, the assessee filed Objection No. 222 dated 22.04.2021 before the Ld. DRP. One of the consortium members M/s. Deepali Design & Exhibits Pvt. Ltd. also filed an Objection No.221 dated

Pico Deepali Overlays Consortium, Haryana vs. DCIT Central Circle 17, Delhi

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

ITA 412/DEL/2022[2011-12]Status: DisposedITAT Delhi10 Dec 2025AY 2011-12

Section 144CSection 153ASection 92C

Raghvendra Singh, Howrah vs. Income Tax Officer, Bamboo Villa, Calcutta

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

ITA 1763/KOL/2025[2018-19]Status: DisposedITAT Kolkata09 Dec 2025AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 1763/Kol/2025 Assessment Year: 2018-2019 Raghvendra Singh,……………….………...……Appellant 13, Burnt Salt Gola Lane, Howrah-711101, West Bengal [Pan:Bjhps6740J] -Vs.- Income Tax Officer,…………………………..…..Respondent Ward-62(1), Kolkata, Bamboo Villa, 169, A.J.C. Bose Road, Kolkata-700014 Appearances By: Shri Vidyut Sethi, C.A., Appeared On Behalf Of The Assessee Shri Kallol Mistry, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: November 13, 2025 Date Of Pronouncing The Order: December 09, 2025 O R D E R

Section 142(1)Section 143(2)Section 270ASection 56(2)(x)

Department. The assessment proceedings are getting barred by limitation of time on 30.04.2021 in this case. Therefore, show cause notice dt.19.04.2021 along with draft assessment order was issued through the registered email of the assessee and also 2 Raghvendra Singh shared with the assessee in the e proceedings of assessee

Aruna Jain, Uttar Pradesh vs. DCIT/ACIT, Central Circle, Ghaziabad

In the result, assessee’s appeal is allowed

ITA 6066/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Dec 2025AY 2017-18

Bench: Shri S Rifaur Rahman & Ms. Madhumita Royassessment Year: 2017-18

Section 132Section 139(1)Section 143(3)Section 144BSection 153Section 153ASection 153DSection 250Section 68

Extract of the approval is reproduced for ready reference of your honours: 5 "2. In the context of captioned matter, the approval of draft assessment orders in the following cases are hereby accepted as per the details given below:- S. No. Name of the Assessee PAN A.Y. Section ... complexity of search assessments, it is humanly improbable for the approving authority to meaningfully examine the records, seized material, and proposed draft assessment orders of such a large number of cases and thereafter grant judicious and reasoned approval within one day. (b) Approval granted without examination of assessment records

Mukesh Kumar, Ludhiana vs. ITO Ward 2(1), Ludhiana

In the result, Assessee’s appeal is allowed

ITA 917/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh08 Dec 2025AY 2017-18

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 917/Chd/2025 "नधा"रण वष" / Assessment Year : 2017-18 Mukesh Kumar, Ito, Prop. Ravindra Chemical & बनाम Ito Ward 2(1), General Agencies, Ludhiana Vs. Talab Bazar, Ludhiana "थायी लेखा सं./ Pan No: Acjpk8421A अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT

Section 115BSection 139(1)Section 147Section 148Section 250Section 68Section 69A

Further, it is submitted that during the assessment proceedings, vide his reply dtd. 23.03.2022 to the SCN cum draft assessment order issued by the ld. AO discharged its burden by clearly explaining that the deposits of Rs. 10.46 lakh represented cash sales made in the ordinary course of business

Dasari Sai Annapurna L/R of Late Dasari Gopi Krishna Reddy, Vijayawada vs. The Assistant Commissioner of Income Tax, Central Circle-2(1), Vijayawada

In the result, the appeal of the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 583/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2015-16

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.583/Viz/2025 (िनधा"रण वष"/Assessment Year:2015-16) Dasari Sai Annapurna Vs. Assistant Commissioner L/R Of Late Dasari Gopi Of Income Tax, Krishna Reddy, Central Circle-2(1), Vijayawada. Vijayawada. Pan: Aeipd0990C (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Mv Prasad, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 27/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 08/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 28/03/2022, For The Assessment Year 2015-16. The 2 Dasai Sai Annapurna L/R Of Late Dasari Gopi Krishna Reddy Vs. Acit

For Appellant: Shri MV Prasad, CAFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 143(2)Section 147Section 148Section 45Section 54F

best of his judgment under section 147 r.w.s 144 r.w.s 144B of the Act. Considering the merits of the case, a draft assessment order was served upon the assessee along with a show cause notice (SCN), dated 22/03/2022. 5 Dasai Sai Annapurna L/R of Late Dasari Gopi Krishna Reddy