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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

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

In the result, appeals of the assessee for A

ITA 1254/CHANDI/2024[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

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

In the result, appeals of the assessee for A

ITA 1253/CHANDI/2024[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

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

In the result, appeals of the assessee for A

ITA 1252/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh16 Oct 2025AY 2015-16

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

Michael Page International Recruitment Pvt Ltd, Mumbai vs. DCIT Circle 14(1)(1), Mumbai

ITA 6748/MUM/2024[2021-22]Status: DisposedITAT Mumbai16 Oct 2025AY 2021-22
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 37Section 41Section 92D

availed by the Assessee as `Nil' and proposed an upward transfer pricing adjustment of INR.19,42,69,527/-. 6. The Assessing Officer passed Draft Assessment Order, dated 12/12/2023, under Section 143(3) read with Section 144C(1) of the Act proposing transfer pricing adjustment of INR.19 ... Assessee filed objections before the DRP against the Draft Assessment Order. During the DRP proceedings, the Assessee reiterated its submissions made before the TPO and also filed further documentary evidence as additional evidence which was admitted by the DRP. However, vide Order dated 25/09/2024, the DRP rejected the objections raised

Synacor Inc., Hamburg vs. ACIT, Int.Tax. Circle- 3(1)(2), Delhi

In the result, impugned order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1802/DEL/2025[2018-19]Status: DisposedITAT Delhi16 Oct 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.1802/िद"ी/2025(िन.व. 2018-19) Synacor Inc. 485, Sunset Drive, Office #114, Hamburg, Ny 14075 ...... अपीलाथ"/Appellant Pan: Aaxcs-8643-K बनाम Vs. Assistant Commissioner Of Income Tax, International Taxation, Circle 3(1)(2), ..... "ितवादी/Respondent Civic Centre, Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By : Shri Deepak Chopra, Ms. Priya Tandon & Ms. Seetal Kandpal, Advocates "ितवादी"ारा/Respondent By : Shri M.S Nethrapal, Cit(Dr) सुनवाई क" ितिथ/ Date Of Hearing : 16/10/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 16/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 15.01.2025, Passed U/S. 147 R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2018-19. 2. Shri Deepak Chopra, Appearing On Behalf Of The Assessee At The Outset Submitted That Though The Assessee Has Raised Multiple Grounds Of Appeal, However, The Effective Grounds Assailing The Addition By Treating Sale Of Software Licenses As Fee For Technical Services (Fts) Are Ground No. 8, 10 & 16 Of Appeal.

For Appellant: Shri Deepak Chopra, Ms. Priya Tandon &For Respondent: Shri M.S Nethrapal, CIT(DR)
Section 147

Total 10,87,45,153 1,04,97,645 3. The ld. Counsel submits that the Assessing Officer (AO) in draft assessment order has observed that factual matrix in the impugned assessment year is same as that of assessment year 2021-22. The findings for assessment year 2021-22 were

Sanjay Kumar Karnani, Jaipur vs. ACIT, Central Circle-3, Jaipur

ITA 675/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Oct 2025AY 2018-19
Section 153ASection 250Section 68

आIT A Nos.56 to 61/JP/2025 Shri Ambika Garments vs. ACIT आयकर अपीलीय अधिकरण, जयपुर न्यायाधी, जयपुर IN THE INCOME TAX

Sanjay Kumar Karnani, Jaipur vs. ACIT, Central Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

ITA 673/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Oct 2025AY 2016-17

Bench: AO on 12-04-2021 18. Reply filed before AO on 15-07-2021 19. Additional Written Submissions filed before CIT(A) for AY 2014-15 on 11-11-2024 20. Written Submissions filed before CIT(A) for AY 2014-15 21. Written Submissions filed before CIT(A) for AY 2015-16 on 10-10-2024 22. Written Submissions filed before CIT(A) for AY 2016-17 on 10-10-2024 23. Written Submissions filed before CIT(A) for AY 2017-18 on 15-10-2024 24. Written Submissions filed before CIT(A) for AY 2018-19 on 15-10-2024 25.

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh

Sanjay Kumar Karnani, Jaipur vs. ACIT, Central Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

ITA 672/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Oct 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh

Shri Ambica Garments, Jodhpur vs. ACIT, Central Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

ITA 61/JPR/2025[2019-20]Status: DisposedITAT Jaipur15 Oct 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh

Shri Ambica Garments, Jodhpur vs. ACIT, Cental Circle-3, Jaipur, Jodhpur

In the result, all appeals of the assessee are disposed off in terms of

ITA 59/JPR/2025[2017-18]Status: DisposedITAT Jaipur15 Oct 2025AY 2017-18
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh

Shri Ambica Garments, Jodhpur vs. ACIT, Cental Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

ITA 57/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Oct 2025AY 2015-16
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh

Shri Ambica Garments, Jodhpur vs. ACIT, Cental Circle-3, Jaipur

ITA 56/JPR/2025[2014-15]Status: DisposedITAT Jaipur15 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

ACIT the rank of the Joint Commissioner of Income Tax (“JCIT”) is required to obtain prior approval u/s 153D by forwarding the draft assessment order before passing the final assessment order under Section 153A read with Section 143(3) in cases arising out of a search. 1.2 In compliance with ... material placed before it. 2.2 The Ld. Joint CIT in all the cases has merely recorded a bald statement that “the draft assessment order in the following cases submitted by you are hereby approved u/s 153D of Income Tax Act, 1961”, followed by a tabular list containing basic particulars

Udita Gupta, Jaipur vs. ITO Ward, 1, Kishangarh

11. In view of the above discussion, this appeal is disposed of, for statistical purposes and the matter is restored to the files of the Assessing

ITA 1019/JPR/2025[2020-21]Status: DisposedITAT Jaipur15 Oct 2025AY 2020-21

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Rajeev Sogani, C.AFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 142(1)Section 143(2)

proceeded ex-parte. Show cause notice dated 17.02.2022 was issued to the assessee. It was followed by another show cause notice accompanied by draft assessment order dated 17.03.2022. The assessee, in reply to the said show cause notice, put forth her claim on 30.03.2022 with some details. Therefore, the Assessing ... noticed above, during assessment proceedings, the assessee submitted her response only to the show cause notice dated 17.03.2022, which was accompanied by draft assessment order. In para 2, page 2 of the assessment order, there is detail of the notices issued by the department to the assessee. These details reveal

Shri Dipendra Singh, Tonk vs. ACIT Cen Cir 2, Jaipur

In the result, the appeals of the assessee in ITA

ITA 251/JPR/2024[2018-19]Status: DisposedITAT Jaipur15 Oct 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rohan Sogani, C.AFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 115BSection 143(3)Section 153CSection 250Section 68Section 69Section 69A

drawn to the letter of approval placed on record, which contained only a blanket statement of grant of approval without any reference to draft assessment orders, seized material, or appraisal report. It was contended by the ld. AR of the assessee that the approving authority is statutorily required to examine ... 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/153C. 9. It is submitted that in the present case, the approving authority has granted approval

Shri Dipendra Singh, Tonk vs. ACIT Cen Cir 2, Jaipur

In the result, the appeals of the assessee in ITA

ITA 250/JPR/2024[2017-18]Status: DisposedITAT Jaipur15 Oct 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rohan Sogani, C.AFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 115BSection 143(3)Section 153CSection 250Section 68Section 69Section 69A

drawn to the letter of approval placed on record, which contained only a blanket statement of grant of approval without any reference to draft assessment orders, seized material, or appraisal report. It was contended by the ld. AR of the assessee that the approving authority is statutorily required to examine ... 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/153C. 9. It is submitted that in the present case, the approving authority has granted approval

Shri Dipendra Singh, Tonk vs. ACIT Cen Cir 2, Jaipur

In the result, the appeals of the assessee in ITA

ITA 249/JPR/2024[2015-16]Status: DisposedITAT Jaipur15 Oct 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rohan Sogani, C.AFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 115BSection 143(3)Section 153CSection 250Section 68Section 69Section 69A

drawn to the letter of approval placed on record, which contained only a blanket statement of grant of approval without any reference to draft assessment orders, seized material, or appraisal report. It was contended by the ld. AR of the assessee that the approving authority is statutorily required to examine ... 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/153C. 9. It is submitted that in the present case, the approving authority has granted approval

Shri Dipendra Singh, Tonk vs. ACIT Cen Cir 2, Jaipur

In the result, the appeals of the assessee in ITA

ITA 248/JPR/2024[2014-15]Status: DisposedITAT Jaipur15 Oct 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rohan Sogani, C.AFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 115BSection 143(3)Section 153CSection 250Section 68Section 69Section 69A

drawn to the letter of approval placed on record, which contained only a blanket statement of grant of approval without any reference to draft assessment orders, seized material, or appraisal report. It was contended by the ld. AR of the assessee that the approving authority is statutorily required to examine ... 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/153C. 9. It is submitted that in the present case, the approving authority has granted approval

Shri Dipendra Singh, Tonk vs. ACIT Cen Cir 2, Jaipur

In the result, the appeals of the assessee in ITA

ITA 247/JPR/2024[2013-14]Status: DisposedITAT Jaipur15 Oct 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rohan Sogani, C.AFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 115BSection 143(3)Section 153CSection 250Section 68Section 69Section 69A

drawn to the letter of approval placed on record, which contained only a blanket statement of grant of approval without any reference to draft assessment orders, seized material, or appraisal report. It was contended by the ld. AR of the assessee that the approving authority is statutorily required to examine ... 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/153C. 9. It is submitted that in the present case, the approving authority has granted approval

Ramagopal Varma Ramaraju, Hyderabad vs. ITO, Interenational Taxation-2, Hyderabad

In the result, the appeal filed by the assessee arising from the assessment order passed u/sec

ITA 1302/HYD/2025[2015-16]Status: DisposedITAT Hyderabad15 Oct 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /It(It)A No.507/Hyd/2025 & Ita.No.1302/Hyd./2025 िनधा"रण वष"/Assessment Year 2015-2016 Ramgopal Varma The Income Tax Officer Ramaraju, Hyderabad. Vs. [Int.Taxn]-2, Hyderabad Pin – 500 060. Telangana. Pin - 500 004. Telangana. Pan Arppr7316E (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri S Rama Rao, Advocate Dr. Narendra Kumar Naik, Cit-Dr राज" व "ारा/Revenue By: & Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 15.10.2025 घोषणा की तारीख/Pronouncement: 15.10.2025 आदेश/Order Per Vijay Pal Rao:

For Appellant: Sri S Rama Rao, AdvocateFor Respondent: And Dr. Sachin Kumar, Sr. AR
Section 139(1)Section 144C(1)Section 144C(5)Section 147Section 148Section 69ASection 69C

that there is a deposit of Rs.12,86,000/- on 12.12.2014 in the bank account of the assessee. Thereafter, the Assessing Officer passed Draft Assessment Order u/sec.144C(1) of the Act on 14.02.2024. Against the Draft Assessment Order, the assessee has filed objections before the Disputes Resolution Panel [in short ... Assessing Officer passed assessment order u/sec.147 r.w.s.144 despite the fact that the assessee has already filed objections before the DRP against the Draft Assessment Order within the time as provided under sub-sec.(2) of sec.144(C) of the Act. 5. The learned AR of the Assessee submitted that

Santlal Enterprise, Siliguri vs. ITO, Ward 1(1), Siliguri

In the result, the appeal of the assessee is allowed

ITA 822/KOL/2025[2018-2019]Status: DisposedITAT Kolkata15 Oct 2025AY 2018-2019

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm**

Section 115BSection 250Section 50(2)(x)Section 56(2)(x)Section 68

said notices by filing various details/ evidences before the learned AO electronically. Thereafter, the learned AO issued show cause notice along with draft assessment order on 13.04.2021, calling upon the assessee to furnish various documents along with reasons for disputing draft assessment order. The assessee requested for the adjournment till