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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

Govind Ram Makrania Prop. M/S Laxmi Oil & Ginning Factory, Bhiwani vs. DCIT Central Circle - I, Gurgaon

In the result, the captioned appeals of the Assessees are allowed

ITA 1504/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Oct 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 153CSection 153D

pronouncements, sought for allowing the Appeal and prayed for quashing the assessment order. 4. Per contra, the Ld. Departmental Representative submitted that the draft assessment orders have been perused by the Joint Commissioner of Income Tax,Central Range Gurugram, while according approval u/s 153D of the Act on 30/12/2019 ... 20/05/2024 at 21:34:51 requires the approving authority, i.e. Joint Commissioner to verify the issues raised by the 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

Deputy Commissioner of Income Tax Central Circle - 16, Delhi vs. Sahil Kohli, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 3283/DEL/2023[2015-16]Status: DisposedITAT Delhi17 Oct 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 143(2)Section 153ASection 250

from the perusal of the approval, it could be seen that Adl. CIT while granting approval has observed that he has perused the draft assessment order and case records, without referring to any material which was considered by him such as seized material, including replies filed by the assessee with ... reference to the additions/ disallowance proposed in the drafts assessment order, etc. It was pointed out that the mandate of law u/s 153D is that the approval should be granted with an independent mind after considering the material on record for each assessment year in respect of each assessee separately

Deputy Commissioner of Income Tax, Central Circle-16, Delhi vs. Kohli Tents Private Limited, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2956/DEL/2023[2013-14]Status: DisposedITAT Delhi17 Oct 2025AY 2013-14

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 139(1)Section 143(2)Section 153ASection 250

from the perusal of the approval, it could be seen that Adl. CIT while granting approval has observed that he has perused the draft assessment order and case records, without referring to any material which was considered by him such as seized material, including replies filed by the assessee with ... Nos.2956/Del/2023 & Others reference to the additions/ disallowance proposed in the drafts assessment order, etc. It was pointed out that the mandate of law u/s 153D is that the approval should be granted with an independent mind after considering the material on record for each assessment year in respect of each

Deputy Commissioner of Income Tax, Central Circle-16, Delhi vs. Key Events, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2740/DEL/2023[2017-18]Status: DisposedITAT Delhi17 Oct 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 143(2)Section 153CSection 250Section 69A

from the perusal of the approval, it could be seen that Adl. CIT while granting approval has observed that he has perused the draft assessment order and case records, without referring to any material which was considered by him such as seized material, including replies filed by the assessee with ... reference to the additions/ disallowance proposed in the drafts assessment order, etc. It was pointed out that the mandate of law u/s 153D is that the approval should be granted with an independent mind after considering the material on record for each assessment year in respect of each assessee separately

Deputy Commissioner of Income Tax, Central Circle-16, Delhi vs. Key Events, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2700/DEL/2023[2018-19]Status: DisposedITAT Delhi17 Oct 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 143(2)Section 153CSection 250Section 69A

from the perusal of the approval, it could be seen that Adl. CIT while granting approval has observed that he has perused the draft assessment order and case records, without referring to any material which was considered by him such as seized material, including replies filed by the assessee with ... reference to the additions/ disallowance proposed in the drafts assessment order, etc. It was pointed out that the mandate of law u/s 153D is that the approval should be granted with an independent mind after considering the material on record for each assessment year in respect of each assessee separately

Deputy Commissioiner of Income Tax, Delhi vs. Key Events, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2699/DEL/2023[2016-17]Status: DisposedITAT Delhi17 Oct 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 143(2)Section 153CSection 250Section 69A

from the perusal of the approval, it could be seen that Adl. CIT while granting approval has observed that he has perused the draft assessment order and case records, without referring to any material which was considered by him such as seized material, including replies filed by the assessee with ... reference to the additions/ disallowance proposed in the drafts assessment order, etc. It was pointed out that the mandate of law u/s 153D is that the approval should be granted with an independent mind after considering the material on record for each assessment year in respect of each assessee separately

Deputy Commissioner of Income Tax Central Circle-16 Delhi, Delhi vs. Kohli Tents Private Limited, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2597/DEL/2023[2018-19]Status: DisposedITAT Delhi17 Oct 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 139(1)Section 143(2)Section 153ASection 250

from the perusal of the approval, it could be seen that Adl. CIT while granting approval has observed that he has perused the draft assessment order and case records, without referring to any material which was considered by him such as seized material, including replies filed by the assessee with ... Nos.2956/Del/2023 & Others reference to the additions/ disallowance proposed in the drafts assessment order, etc. It was pointed out that the mandate of law u/s 153D is that the approval should be granted with an independent mind after considering the material on record for each assessment year in respect of each

Deputy Commissioner of Income Tax Central Circle 16 Delhi, Delhi vs. Kohli Tents Private Limited, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2596/DEL/2023[2016-17]Status: DisposedITAT Delhi17 Oct 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 139(1)Section 143(2)Section 153ASection 250

from the perusal of the approval, it could be seen that Adl. CIT while granting approval has observed that he has perused the draft assessment order and case records, without referring to any material which was considered by him such as seized material, including replies filed by the assessee with ... Nos.2956/Del/2023 & Others reference to the additions/ disallowance proposed in the drafts assessment order, etc. It was pointed out that the mandate of law u/s 153D is that the approval should be granted with an independent mind after considering the material on record for each assessment year in respect of each

Deputy Commissioner of Income Tax Central Circle 16 Delhi, Delhi vs. Kohli Tents Private Limited, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2595/DEL/2023[2015-16]Status: DisposedITAT Delhi17 Oct 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 139(1)Section 143(2)Section 153ASection 250

from the perusal of the approval, it could be seen that Adl. CIT while granting approval has observed that he has perused the draft assessment order and case records, without referring to any material which was considered by him such as seized material, including replies filed by the assessee with ... Nos.2956/Del/2023 & Others reference to the additions/ disallowance proposed in the drafts assessment order, etc. It was pointed out that the mandate of law u/s 153D is that the approval should be granted with an independent mind after considering the material on record for each assessment year in respect of each

Deputy Commissioner of Income Tax Central Circle - 16, Delhi vs. Kohli Tents Private Limited, New Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2594/DEL/2023[2014-15]Status: DisposedITAT Delhi17 Oct 2025AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 139(1)Section 143(2)Section 153ASection 250

from the perusal of the approval, it could be seen that Adl. CIT while granting approval has observed that he has perused the draft assessment order and case records, without referring to any material which was considered by him such as seized material, including replies filed by the assessee with ... Nos.2956/Del/2023 & Others reference to the additions/ disallowance proposed in the drafts assessment order, etc. It was pointed out that the mandate of law u/s 153D is that the approval should be granted with an independent mind after considering the material on record for each assessment year in respect of each

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Aman Feed Industries, Khanna

In the result, appeals of the assessee for A

ITA 457/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh16 Oct 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 145(3)Section 153ASection 153DSection 250Section 68

thereafter approved these orders. However, no such documents have been referred by the AO in her forwarding letter. She has only sent draft assessment orders relating to AFI Group. He pointed out that after draft orders of assessee group for six years are looked into, then they themselves are more ... apply to section 153D of the Act. There are three or four requirements that are mandated therein, (i) the AO should submit the draft assessment order "well in time". Here it was submitted just two days prior to the deadline thereby putting the approving authority under great pressure

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. M/S Afi Agro Pvt. Ltd., Khanna

In the result, all the appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 373/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh16 Oct 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1256, 1257,1258/Chd/2024 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 Afi Agro Private Limited, The Dcit, A-1, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 179,180,373/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs Afi Agro Private Limited, Central Circle-1, A-1, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms. Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025 Physical Hearing O R D E R Per Raj Pal Yadav, Vp

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 132Section 139(1)Section 139(4)Section 143(2)Section 153ASection 153D

thereafter approved these orders. However, no such documents have been referred by the AO in her forwarding letter. She has only sent draft assessment orders relating to AFI Group. He pointed out that after draft orders of assessee group for six years are looked into, then they themselves are more ... apply to section 153D of the Act. There are three or four requirements that are mandated therein, (i) the AO should submit the draft assessment order "well in time". ITA Nos.1256 to 1258/CHD/2024 & ITA Nos.179, 180 & 373/CHD/2025 17 Here it was submitted just two days prior to the deadline thereby

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Aman Feed Industries, Khanna

In the result, appeals of the assessee for A

ITA 181/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh16 Oct 2025AY 2018-19

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 145(3)Section 153ASection 153DSection 250Section 68

thereafter approved these orders. However, no such documents have been referred by the AO in her forwarding letter. She has only sent draft assessment orders relating to AFI Group. He pointed out that after draft orders of assessee group for six years are looked into, then they themselves are more ... apply to section 153D of the Act. There are three or four requirements that are mandated therein, (i) the AO should submit the draft assessment order "well in time". Here it was submitted just two days prior to the deadline thereby putting the approving authority under great pressure

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Afi Agro Pvt. Ltd., Khanna

In the result, all the appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 180/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh16 Oct 2025AY 2018-19

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1256, 1257,1258/Chd/2024 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 Afi Agro Private Limited, The Dcit, A-1, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 179,180,373/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs Afi Agro Private Limited, Central Circle-1, A-1, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms. Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025 Physical Hearing O R D E R Per Raj Pal Yadav, Vp

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 132Section 139(1)Section 139(4)Section 143(2)Section 153ASection 153D

thereafter approved these orders. However, no such documents have been referred by the AO in her forwarding letter. She has only sent draft assessment orders relating to AFI Group. He pointed out that after draft orders of assessee group for six years are looked into, then they themselves are more ... apply to section 153D of the Act. There are three or four requirements that are mandated therein, (i) the AO should submit the draft assessment order "well in time". ITA Nos.1256 to 1258/CHD/2024 & ITA Nos.179, 180 & 373/CHD/2025 17 Here it was submitted just two days prior to the deadline thereby

Deputy Commissioner of Income Tax, CC-1, Ludhiana vs. Afi Agro Pvt. Ltd., Khanna

In the result, all the appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 179/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh16 Oct 2025AY 2017-18

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1256, 1257,1258/Chd/2024 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 Afi Agro Private Limited, The Dcit, A-1, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 179,180,373/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs Afi Agro Private Limited, Central Circle-1, A-1, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms. Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025 Physical Hearing O R D E R Per Raj Pal Yadav, Vp

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 132Section 139(1)Section 139(4)Section 143(2)Section 153ASection 153D

thereafter approved these orders. However, no such documents have been referred by the AO in her forwarding letter. She has only sent draft assessment orders relating to AFI Group. He pointed out that after draft orders of assessee group for six years are looked into, then they themselves are more ... apply to section 153D of the Act. There are three or four requirements that are mandated therein, (i) the AO should submit the draft assessment order "well in time". ITA Nos.1256 to 1258/CHD/2024 & ITA Nos.179, 180 & 373/CHD/2025 17 Here it was submitted just two days prior to the deadline thereby

Dy. Commissioner of Income Tax, CC-1, Ludhiana vs. M/S Aman Feed Industries, Khanna

In the result, appeals of the assessee for A

ITA 116/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh16 Oct 2025AY 2017-18

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 145(3)Section 153ASection 153DSection 250Section 68

thereafter approved these orders. However, no such documents have been referred by the AO in her forwarding letter. She has only sent draft assessment orders relating to AFI Group. He pointed out that after draft orders of assessee group for six years are looked into, then they themselves are more ... apply to section 153D of the Act. There are three or four requirements that are mandated therein, (i) the AO should submit the draft assessment order "well in time". Here it was submitted just two days prior to the deadline thereby putting the approving authority under great pressure

Afi Agro Private Limited, Khanna vs. Deputy Commissioner of Income Tax, CC-1, Ludhiana

In the result, all the appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 1258/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh16 Oct 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1256, 1257,1258/Chd/2024 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 Afi Agro Private Limited, The Dcit, A-1, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 179,180,373/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs Afi Agro Private Limited, Central Circle-1, A-1, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms. Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025 Physical Hearing O R D E R Per Raj Pal Yadav, Vp

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 132Section 139(1)Section 139(4)Section 143(2)Section 153ASection 153D

thereafter approved these orders. However, no such documents have been referred by the AO in her forwarding letter. She has only sent draft assessment orders relating to AFI Group. He pointed out that after draft orders of assessee group for six years are looked into, then they themselves are more ... apply to section 153D of the Act. There are three or four requirements that are mandated therein, (i) the AO should submit the draft assessment order "well in time". ITA Nos.1256 to 1258/CHD/2024 & ITA Nos.179, 180 & 373/CHD/2025 17 Here it was submitted just two days prior to the deadline thereby

Afi Agro Private Limited, Khanna vs. Deputy Commissioner of Income Tax, CC-1, Ludhiana

In the result, all the appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 1257/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh16 Oct 2025AY 2018-19

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1256, 1257,1258/Chd/2024 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 Afi Agro Private Limited, The Dcit, A-1, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 179,180,373/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs Afi Agro Private Limited, Central Circle-1, A-1, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms. Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025 Physical Hearing O R D E R Per Raj Pal Yadav, Vp

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 132Section 139(1)Section 139(4)Section 143(2)Section 153ASection 153D

thereafter approved these orders. However, no such documents have been referred by the AO in her forwarding letter. She has only sent draft assessment orders relating to AFI Group. He pointed out that after draft orders of assessee group for six years are looked into, then they themselves are more ... apply to section 153D of the Act. There are three or four requirements that are mandated therein, (i) the AO should submit the draft assessment order "well in time". ITA Nos.1256 to 1258/CHD/2024 & ITA Nos.179, 180 & 373/CHD/2025 17 Here it was submitted just two days prior to the deadline thereby

Afi Agro Private Limited, Khanna vs. Deputy Commissioner of Income Tax, CC-1, Ludhiana

In the result, all the appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 1256/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh16 Oct 2025AY 2017-18

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1256, 1257,1258/Chd/2024 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 Afi Agro Private Limited, The Dcit, A-1, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 179,180,373/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs Afi Agro Private Limited, Central Circle-1, A-1, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms. Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025 Physical Hearing O R D E R Per Raj Pal Yadav, Vp

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 132Section 139(1)Section 139(4)Section 143(2)Section 153ASection 153D

thereafter approved these orders. However, no such documents have been referred by the AO in her forwarding letter. She has only sent draft assessment orders relating to AFI Group. He pointed out that after draft orders of assessee group for six years are looked into, then they themselves are more ... apply to section 153D of the Act. There are three or four requirements that are mandated therein, (i) the AO should submit the draft assessment order "well in time". ITA Nos.1256 to 1258/CHD/2024 & ITA Nos.179, 180 & 373/CHD/2025 17 Here it was submitted just two days prior to the deadline thereby

Aman Feed Industries, Khanna vs. Deputy Commissioner of Income Tax, CC-1, Ludhiana

In the result, appeals of the assessee for A

ITA 1255/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh16 Oct 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 145(3)Section 153ASection 153DSection 250Section 68

thereafter approved these orders. However, no such documents have been referred by the AO in her forwarding letter. She has only sent draft assessment orders relating to AFI Group. He pointed out that after draft orders of assessee group for six years are looked into, then they themselves are more ... apply to section 153D of the Act. There are three or four requirements that are mandated therein, (i) the AO should submit the draft assessment order "well in time". Here it was submitted just two days prior to the deadline thereby putting the approving authority under great pressure