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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

Amarjot Singh, Gurdaspur vs. Income Tax Officer Ward Gurdaspur, Gurdaspur

In the result, all the five appeals filed by the assessee are allowed for statistical

ITA 597/ASR/2024[2015-2016]Status: DisposedITAT Amritsar07 Oct 2025AY 2015-2016

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. P. N. Arora, Adv
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 69

response to return submitted u/s 148, even though, we find that the return has been filed by the assessee after receipt of the draft assessment order and the same has been filed after 11 (eleven) months from the date of service of notice u/s 148. 8. Moreover, on merits ... been any response from the assessee in respect of various notices issued, and the assessee has filed the return after receipt of the draft assessment order, which means the assessee was already in knowledge of the entire concealment and details of escaped income before filing the return which has been

Kataria Snack Pellets Private Limited, Rajkot vs. Assistant Commissioner of Income Tax, Circle-1(1), Rajkot

In the result, appeal of the assessee is dismissed

ITA 468/RJT/2024[2015-16]Status: DisposedITAT Rajkot07 Oct 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.468/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2015-16 Kataria Snack Pellets Pvt. Ltd. The Acit, Circle-1(1) बनाम 510, Gidc, Metoda Kalawad Road Rajkot Rajkot-360021, Gujarat Vs. Pan : Aafck2028L (अपीलाथ"/Appellant) (""यथ"/Respondent) :

For Appellant: Shri Nishit B. Jesur, ld.ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(2)Section 143(3)Section 147Section 148Section 250Section 56(2)(vii)

Thereafter, again A Show-Cause notice (SCN) was issued by the assessing officer to the assessee on 27.03.2022. The Draft Assessment Order (DAO) Kataria Snack Pellets Pvt. Ltd. ITA No.468 /RJT/2024 (AY : 2015-16) 10 proposing to make addition of the above-mentioned amount to the total income ... assesse has been considered but the growth approaches taken while valuing the share using DCF method is nowhere the actual figure. In the Draft assessment order, it was clearly mentioned that the valuer has not submitted the basis of the estimation on the basis of which it estimates that

Jagdish Solanki, Jhabua vs. Income Tax Officer Jhabua, Jhabua

ITA 169/IND/2025[2017-18]Status: DisposedITAT Indore07 Oct 2025AY 2017-18

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

आयकर अपीलीय अधिकरण, इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT

Malwa Oxygen and Industrial Gases Private Limited, Sector C, Industrial Area vs. AO-Ratlam/Income Tax Officer, NFAC, Ratlam/Delhi

Appeal is partly allowed for statistical purposes

ITA 713/IND/2024[2018-19]Status: DisposedITAT Indore07 Oct 2025AY 2018-19

Bench: Shri B.M. Biyani

Section 143(3)Section 35Section 35(1)

assessee is only an after-thought when the deduction was disallowed. Therefore, request of the Assessee is rejected. 2.7 Show cause notice alongwith Draft assessment order was sent to the assessee on 10/04/2021 and assessee replied on 11/04/2021. Reply of the assessee is considered carefully but not found acceptable

M/S. Tbea Shenyang Trasformer Group Company Limited, Vadodara vs. The Deputy Commissioner of Income Tax, Int. Tax., Vadodara

Appeal is dismissed

ITA 121/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad07 Oct 2025AY 2013-14

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2013-2014 M/S.Tbea Shenyang Transformer Dcit, International Group Company Limited Vs. Taxation Tbea Green Energy Park Vadodara. National Highway No.8 Village : Miyagam Karjan Vadodara Pan : Aadct 4557 F (Applicant) (Responent) : Assessee By Ms.Amrin Pathan, Ar : Shri Mahesh Shah, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 29/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/10/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Arises From The Assessment Order Dated 07.11.2017 Passed By The Deputy Commissioner Of Income Tax, International Taxation, Vadodara [Hereinafter Referred To As “Assessing Officer Or Ao”], Under Section 143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 For Assessment Year 2013-14 In Accordance With The Directions Of The Dispute Resolution Panel – 2, Mumbai [Hereinafter Referred To As “Drp”]

Section 142(1)Section 143(2)Section 143(3)Section 144C(13)Section 144C(2)Section 144C(5)Section 271(1)(c)Section 92BSection 92CSection 92E

portion extracted in the assessment order, the upward adjustment figure appears as Rs.9,09,30,132/-. Based on the TPO’s order, a draft assessment order dated 29.12.2016 was passed and served on the assessee on 02.01.2017. 2.3 The assessee filed objections before the Dispute Resolution Panel (DRP) under section

Sp Armada Oil Exploration Private Limited, Mumbai vs. Deputy Commissioner of Income Tax- Circle 3(3)(1), Mumbai

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

ITA 6575/MUM/2024[2021-22]Status: DisposedITAT Mumbai06 Oct 2025AY 2021-22

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailsp Armada Oil Exploration Private Limited 404, Trade Centre, Bandra Kurla Complex, Bandra (East), Mumbai 400051. Pan: Aaqcs7983P ............... Appellant

For Appellant: Shri Mukesh Butani a/w Shri Pratik PoddarFor Respondent: Shri. Pravin Salunkhe & Shri Aditya M. Rai
Section 143(2)Section 143(3)Section 234ASection 253(1)Section 92C(1)Section 92C(2)Section 92C(3)

conformity with the order passed by the TPO under section 92CA(3) of the Act, the AO passed the draft assessment order dated 18/12/2023 under section 144C(1) of the Act, determining the total income of the assessee at Rs. 42,11,15,317 after making the transfer pricing adjustment

Pratt & Whitney Canada Corp., Canada vs. Deputy Commissioner of Income Tax, International Taxation, Circle 2(2)(2), New Delhi

In the result, assessee’s appeals in ITA No

ITA 666/DEL/2025[2022-23]Status: DisposedITAT Delhi06 Oct 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Rajan Vohra, CAFor Respondent: Shri Nikhil Kumar Govila, CIT-DR
Section 133(6)Section 147Section 153Section 234ASection 234B

held the same to be taxable under the provisions of the Act as well as India - Canada DTAA. 12. The Assessing Officer passed draft assessment order under section 144C(1) of the Act on 23.03.2024 and held that the payments received from the Indian customers on account of repair, maintenance

Pratt & Whitney Canada Corp., Canada vs. Deputy Commissioner of Income Tax, International Taxation, Circle 2(2)(2), New Delhi

In the result, assessee’s appeals in ITA No

ITA 665/DEL/2025[2018-19]Status: DisposedITAT Delhi06 Oct 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Rajan Vohra, CAFor Respondent: Shri Nikhil Kumar Govila, CIT-DR
Section 133(6)Section 147Section 153Section 234ASection 234B

held the same to be taxable under the provisions of the Act as well as India - Canada DTAA. 12. The Assessing Officer passed draft assessment order under section 144C(1) of the Act on 23.03.2024 and held that the payments received from the Indian customers on account of repair, maintenance

Pratt & Whitney Canada (Sea) Pte. Ltd., Singapore vs. Deputy Commissioner of Income Tax, International Taxation, Circle 2(2)(2), New Delhi

In the result, assessee’s appeals in ITA No

ITA 626/DEL/2025[2022-23]Status: DisposedITAT Delhi06 Oct 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Rajan Vohra, CAFor Respondent: Shri Nikhil Kumar Govila, CIT-DR
Section 133(6)Section 147Section 153Section 234ASection 234B

held the same to be taxable under the provisions of the Act as well as India - Canada DTAA. 12. The Assessing Officer passed draft assessment order under section 144C(1) of the Act on 23.03.2024 and held that the payments received from the Indian customers on account of repair, maintenance

Pratt & Whitney Canada (Sea) Pte. Ltd., Singapore vs. Deputy Commissioner of Income Tax, International Taxation, Circle 2(2)(2), New Delhi

In the result, assessee’s appeals in ITA No

ITA 620/DEL/2025[2018-19]Status: DisposedITAT Delhi06 Oct 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Rajan Vohra, CAFor Respondent: Shri Nikhil Kumar Govila, CIT-DR
Section 133(6)Section 147Section 153Section 234ASection 234B

held the same to be taxable under the provisions of the Act as well as India - Canada DTAA. 12. The Assessing Officer passed draft assessment order under section 144C(1) of the Act on 23.03.2024 and held that the payments received from the Indian customers on account of repair, maintenance

Lummus Technology Heat Transfer B.V, Gurugram vs. The Assistant Commissioner of Income Tax, Int. Tax, Gurugram

In the result, appeal of the assessee is allowed

ITA 3741/DEL/2023[2021-22]Status: DisposedITAT Delhi06 Oct 2025AY 2021-22

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.3741/िद"ी/2023(िन.व. 2021-22) Lummus Technology Heat Transfer B.V, Second Floor, Infinity Tower B, Dlf Cyber City, Sector 25A, Phase Ii, Gurugram, Haryana 122001 ...... अपीलाथ"/Appellant Pan: Aabca-9045-K बनाम Vs. Assistant Commissioner Of Income Tax, International Taxation, Gurugram, ..... "ितवादी/Respondent Haryana 122001 अपीलाथ" "ारा/ Appellant By : Shri Vishal Kalra, Advocate, Ms. Reema Grewal, Chartered Accountant & Ms. Snigdha Gautam, Advocate "ितवादी"ारा/Respondent By : Shri Nikhil Kumar Govila, Cit सुनवाई क" ितिथ/ Date Of Hearing : 07/07/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 06/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 27.10.2023, Passed U/S. 143(3) R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’). 2. The Gist Of Grounds Raised By The Assessee In Appeal Assailing The Assessment Order Is As Under:

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri Nikhil Kumar Govila, CIT
Section 143(3)Section 40Section 80G

direct transactions between the head office and Indian customers. In the name of reply, he took us through certain portions of the draft assessment order in which there is a reference to certain invoices of the HO indicating the role of the assessee in such direct transactions. On a careful

Aparna Sandeep Kulkarani, Mumbai vs. Income Tax Officer Int Tax Ward 3(1)(1), Mumbai

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

ITA 909/MUM/2025[2015-16]Status: DisposedITAT Mumbai03 Oct 2025AY 2015-16

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2015-16 Aparna Sandeep Kulkarni, Income Tax Officer, 201A, Kanchanjanga, Int. Tax. Ward-3(1)(1), Sector 12-A, Plot No.12, Vs. Kautilya Bhavan, Koparkhairane, Bandra Kurla Complex, Navi Mumbai-400709. Bandra (East), Pan : Axfpk0077M Mumbai-400051. (Appellant) (Respondent) For Assessee : Shri Ketan L. Vajani For Revenue : Shri Krishna Kumar, Sr.Dr Date Of Hearing : 17-07-2025 Date Of Pronouncement : 03-10-2025 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Shri Ketan L. VajaniFor Respondent: Shri Krishna Kumar, Sr.DR
Section 143(2)Section 147Section 148Section 56(2)(vii)

erred in confirming the addition of Rs. 28,93,400/- u/s. 56(2)(vii)(b) of the Act as per the Draft Assessment Order. The DRP has erred in not appreciating correct facts of the case while confirming the impugned addition. 2 2. The DRP has erred in not appreciating ... However, there was no compliance on the part of the assessee, thereafter, basis information available on record, the AO proceeded and passed the draft assessment order wherein the amount of Rs. 28,93,400/- was brought to tax as income from other sources. 3. The assessee thereafter filed objections before

Jeevan Jyoti Infrastructure Company Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 56/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

another part (i.e. Part-3) COMMON PAPER BOOK – PART-3 S.No. Description of documents enclosed 1. - Assessing Officer's letter (alongwith “corrected/revised draft assessment orders” soliciting Approval u/s 153D in the various cases), dated 28/07/2017 83 COMMON PAPER BOOK – PART4 85 Revenue’s Appeal I.T.A. No.39 to 41/All/2025 & assessee ... contended that the approvals were given without due application of mind. In this regard he drew our attention to the fact that the draft assessment orders were sent to the JCIT by the Assessing Officer vide letter F.No.ACIT/CC/Approval/Alld/2017-18/352 dated 28/07/2017. He further drew our attention to the fact that

Minto Colonizers Private Limited, Allahabad vs. DCIT Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 54/ALLD/2025[2009-10]Status: DisposedITAT Allahabad30 Sept 2025AY 2009-10

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

another part (i.e. Part-3) COMMON PAPER BOOK – PART-3 S.No. Description of documents enclosed 1. - Assessing Officer's letter (alongwith “corrected/revised draft assessment orders” soliciting Approval u/s 153D in the various cases), dated 28/07/2017 83 COMMON PAPER BOOK – PART4 85 Revenue’s Appeal I.T.A. No.39 to 41/All/2025 & assessee ... contended that the approvals were given without due application of mind. In this regard he drew our attention to the fact that the draft assessment orders were sent to the JCIT by the Assessing Officer vide letter F.No.ACIT/CC/Approval/Alld/2017-18/352 dated 28/07/2017. He further drew our attention to the fact that

Deputy Commissioner of Income Tax, Allahabad vs. Navjeevan Pediatrics Private Limited, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 44/ALLD/2025[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

another part (i.e. Part-3) COMMON PAPER BOOK – PART-3 S.No. Description of documents enclosed 1. - Assessing Officer's letter (alongwith “corrected/revised draft assessment orders” soliciting Approval u/s 153D in the various cases), dated 28/07/2017 83 COMMON PAPER BOOK – PART4 85 Revenue’s Appeal I.T.A. No.39 to 41/All/2025 & assessee ... contended that the approvals were given without due application of mind. In this regard he drew our attention to the fact that the draft assessment orders were sent to the JCIT by the Assessing Officer vide letter F.No.ACIT/CC/Approval/Alld/2017-18/352 dated 28/07/2017. He further drew our attention to the fact that

Deputy Commissioner of Income Tax (Central Circle), Allahabad vs. Jeevan Jyoti Charitable Trust, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 41/ALLD/2025[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

another part (i.e. Part-3) COMMON PAPER BOOK – PART-3 S.No. Description of documents enclosed 1. - Assessing Officer's letter (alongwith “corrected/revised draft assessment orders” soliciting Approval u/s 153D in the various cases), dated 28/07/2017 83 COMMON PAPER BOOK – PART4 85 Revenue’s Appeal I.T.A. No.39 to 41/All/2025 & assessee ... contended that the approvals were given without due application of mind. In this regard he drew our attention to the fact that the draft assessment orders were sent to the JCIT by the Assessing Officer vide letter F.No.ACIT/CC/Approval/Alld/2017-18/352 dated 28/07/2017. He further drew our attention to the fact that

Deputy Commissioner of Income Tax, Allahabad vs. Jeevan Jyoti Charitable Trust, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 40/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

another part (i.e. Part-3) COMMON PAPER BOOK – PART-3 S.No. Description of documents enclosed 1. - Assessing Officer's letter (alongwith “corrected/revised draft assessment orders” soliciting Approval u/s 153D in the various cases), dated 28/07/2017 83 COMMON PAPER BOOK – PART4 85 Revenue’s Appeal I.T.A. No.39 to 41/All/2025 & assessee ... contended that the approvals were given without due application of mind. In this regard he drew our attention to the fact that the draft assessment orders were sent to the JCIT by the Assessing Officer vide letter F.No.ACIT/CC/Approval/Alld/2017-18/352 dated 28/07/2017. He further drew our attention to the fact that

Deputy Commissioner of Income Tax(Central Circle), Allahabad vs. Jeevan Jyoti Charitable Trust, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 39/ALLD/2025[2011-12]Status: DisposedITAT Allahabad30 Sept 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

another part (i.e. Part-3) COMMON PAPER BOOK – PART-3 S.No. Description of documents enclosed 1. - Assessing Officer's letter (alongwith “corrected/revised draft assessment orders” soliciting Approval u/s 153D in the various cases), dated 28/07/2017 83 COMMON PAPER BOOK – PART4 85 Revenue’s Appeal I.T.A. No.39 to 41/All/2025 & assessee ... contended that the approvals were given without due application of mind. In this regard he drew our attention to the fact that the draft assessment orders were sent to the JCIT by the Assessing Officer vide letter F.No.ACIT/CC/Approval/Alld/2017-18/352 dated 28/07/2017. He further drew our attention to the fact that

Arpit Hospital Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 14/ALLD/2025[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

another part (i.e. Part-3) COMMON PAPER BOOK – PART-3 S.No. Description of documents enclosed 1. - Assessing Officer's letter (alongwith “corrected/revised draft assessment orders” soliciting Approval u/s 153D in the various cases), dated 28/07/2017 83 COMMON PAPER BOOK – PART4 85 Revenue’s Appeal I.T.A. No.39 to 41/All/2025 & assessee ... contended that the approvals were given without due application of mind. In this regard he drew our attention to the fact that the draft assessment orders were sent to the JCIT by the Assessing Officer vide letter F.No.ACIT/CC/Approval/Alld/2017-18/352 dated 28/07/2017. He further drew our attention to the fact that

Arpit Hospital Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 13/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

another part (i.e. Part-3) COMMON PAPER BOOK – PART-3 S.No. Description of documents enclosed 1. - Assessing Officer's letter (alongwith “corrected/revised draft assessment orders” soliciting Approval u/s 153D in the various cases), dated 28/07/2017 83 COMMON PAPER BOOK – PART4 85 Revenue’s Appeal I.T.A. No.39 to 41/All/2025 & assessee ... contended that the approvals were given without due application of mind. In this regard he drew our attention to the fact that the draft assessment orders were sent to the JCIT by the Assessing Officer vide letter F.No.ACIT/CC/Approval/Alld/2017-18/352 dated 28/07/2017. He further drew our attention to the fact that