“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

Punjab Chemicals & Crop Protection Ltd., Mohali vs. The Additional Commissioner of Income Tax, Range 1, Chandigarh

The appeal stands partly allowed

ITA 316/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh01 Jul 2025AY 2017-18

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 316/Chandi/2022 (िनधा"रणवष" / Assessment Year: 2017-18) Punjab Chemicals & Crop Protection Ltd. Addl. Cit बनाम/ Milestone-18, Ambala-Kalka Road, Range-1 Vpo Bhankharpur, Derabassi Chandigarh Vs. District Sas Nagar Mohali-140201 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacp-9904-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Anil Khanna (Ca). – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Tarundeep Kaur (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 24-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 01-07-2025 आदेश / O R D E R

For Appellant: Sh. Anil Khanna (CA). – Ld. ARFor Respondent: Ms. Tarundeep Kaur (CIT) – Ld. DR

Section 143(3)Section 14ASection 36(1)(iii)Section 92C

made to Ld. Transfer Pricing Officer (TPO) and an order u/s 92CA(3) was passed on 24-01-2021 pursuant to which a draft assessment order was passed by Ld. AO on 23-04-2021 which was objected to by the assessee before Ld. DRP. 1.2 The Ld. AR advanced

Income Tax Officer Ward 10(1) Delhi, Delhi vs. Aruna Gupta, Delhi

ITA 687/DEL/2025[2017-18]Status: DisposedITAT Delhi01 Jul 2025AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 687/Del/2025 : Asstt. Year: 2017-18 Income Tax Officer, Vs Aruna Gupta, Ward-10(1), B-1/45, Safdarjung Enclave, New Delhi-110002 New Delhi-110029 (Appellant) (Respondent) Pan No. Aakpg2642L Co No. 49/Del/2025 : Asstt. Year: 2017-18 Aruna Gupta, Vs Income Tax Officer, B-1/45, Safdarjung Enclave, Ward-10(1), New Delhi-110029 New Delhi-110002 (Appellant) (Respondent) Pan No. Aakpg2642L Assessee By: Dr. Rakesh Gupta, Adv. & Sh. Deepesh Garg, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 01.07.2025 Date Of Pronouncement: 01.07.2025 Order This Revenue’S Appeal & Assessee’S Cross Objection Co No. 49/Del/2025 For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1071333531(1) Dated 18.12.2024, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Sh. Manoj Kumar, Sr. DR

Section 13ASection 147Section 148Section 148ASection 151Section 29A

section 151. Hence, the orders under section 148A(d) and the notices under section 148 are quashed. As a corollary, the draft assessment orders under section 144B/144C cannot survive and are also quashed. 16. These writ petitions are allowed on the above terms. There will be no order

Vaibhav Global Limited, Jaipur vs. DCIT, CC-4, Jaipur

ITA 1485/JPR/2024[2021-22]Status: DisposedITAT Jaipur30 Jun 2025AY 2021-22

For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR

Section 115JSection 115QSection 143(3)Section 144C(5)Section 36(1)(va)

Rs.19,68,509/- Distributed income u/s 115Q (to be taxed @ 20%) Rs.71,99,99,211/- 4. The assessee has filed objections to the draft assessment order in Form no. 35A on 25.10.2023 before the Dispute Resolution Panel [DRP]. The DRP vide order dated 30.06.2024 given the direction u/s 144C

Madkini Hydro Power Private Limited, Dehradun vs. Income Tax Officer- 4(3), Lucknow

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

ITA 228/LKW/2025[2018-19]Status: DisposedITAT Lucknow30 Jun 2025AY 2018-19

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2018-19 Madkini Hydro Power Private V. The Income Tax Officer 4(3) Limited Lucknow Flat No.4, Ii Floor 3, Scindia House Delhi 110 001 Tan/Pan:Aaecm1420B (Appellant) (Respondent) Appellant By: Shri Shalendera Kishore Singh, Adv. Respondent By: Shri R. K. Agarwal, Cit(Dr) Date Of Hearing: 10 06 2025 Date Of Pronouncement: 30 06 2025 O R D E R

For Appellant: Shri Shalendera Kishore Singh, AdvFor Respondent: Shri R. K. Agarwal, CIT(DR)

Section 115BSection 144Section 68

section 144B (w.e.f. 01.04.2021) was inserted by TOLA, which inter alia, provided a mandatory issuance of a prior show cause notice and a draft assessment order before issuing a final assessment order, and specifically provided that orders issued not in accordance with the procedure of section 144B ITA No.228/LKW/2025 Page ... Assessment Centre (Delhi High Court in W.P(C) 5849/2021) The reasoning of the High Court in these cases that issuance of notice and draft assessment orders are mandatory, has been affirmed by the Supreme Court. 7. BECAUSE, the Assessment Order has been passed after the limitation prescribed under section

Mirza International Limited, Kanpur vs. DCIT Circle 2(1)(1), Kanpur

The appeals of the assessee stand partly allowed

ITA 35/LKW/2022[2017-2018]Status: DisposedITAT Lucknow30 Jun 2025AY 2017-2018

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Shri Akshay Gupta, C.AFor Respondent: Shri Sunil Kumar Rajwanshi, D.R

Section 143(3)Section 40A(7)Section 80Section 92Section 92C

proposed an adjustment of Rs.3,14,89,283/- in respect of transfer of leather shoes by applying external TNMM. Thereafter, a draft assessment order was passed in which following adjustments/disallowances were proposed: 1 Adjustment in respect of Arm’s Rs.3,14,89,283/- Length Price ... demonetization period 2.1 The assessee approached the Hon'ble Dispute Resolution Panel (DRP) agitating the adjustments proposed in the draft assessment order. The Hon'ble DRP did not accept assessee’s objection regarding use of external TNMM by the TPO and upheld ITA Nos. 35 & 158 /LKW/2022 Page

F5 Networks Innovation Private Limited, Hyderabad vs. Income Tax Officer, Ward-17(1), Hyderabad

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

ITA 912/HYD/2024[2020-21]Status: DisposedITAT Hyderabad30 Jun 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Sharath Rao & ShriFor Respondent: Shri Narender Kumar Naik

Section 143(1)Section 143(3)Section 92C

order dated 23.07.2023 proposed upward transfer pricing adjustment of Rs.19,42,30,478/- on account of international transactions. Accordingly, the Ld. AO passed draft assessment order on 29.09.2023. Aggrieved with the draft assessment order, the assessee preferred objections before the Learned Dispute Resolution Panel ('Ld. DRP") and pursuant ... assessee was selected for scrutiny assessment wherein certain addition on account of TP adjustment was made. The AO while finalising the draft assessment order computed the total income after taking into account the income computed under intimation order under section 143(1) of the Act and addition of TP adjustment

Invesco(India) Private Limited, Hyderabad vs. DCIT, Circle -2 (1), Hyderabad

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

ITA 111/HYD/2022[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, Sriram SeshadriFor Respondent: Shri B Bala Krishna, CIT-DR

Section 143(3)Section 144C(5)

from AE. In pursuance to the order passed by the TPO u/sec.92CA(3) of the Act, dated 30.01.2021, the Assessing Officer has passed Draft Assessment Order u/sec.144C of the Act, on 08.04.2021 and determined the total income of the appellant-company at Rs.95,18,58,880/- by making TP adjustment ... goodwill; addition towards disallowance u/sec.14A read with Rule 8D of I.T. Rules, 1962. 4. The appellant-company filed it’s objections against the Draft Assessment Order passed by the 10 ITA.No.111/Hyd./2022 Assessing Officer before the DRP-1, Bengaluru and challenged the various additions made by the Assessing Officer

Mmsh Clinical Research Private Limited, Bangalore vs. DCIT, Circle 2(2)(1), Bangalore

In the result, appeal of the assessee is allowed as indicated above

ITA 2586/BANG/2024[2021-22]Status: DisposedITAT Bangalore30 Jun 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadavassessment Year: 2021-22

For Appellant: Sri Vibhor Ghai V.G., A.RFor Respondent: Dr. K.J. Divya, D.R

Section 143(3)Section 144CSection 92C

whereby the ld. TPO has proposed an adjustment of Rs.5,04,48,986/-. Thereafter, the AO passed draft assessment order on 5.12.2023 making the adjustment proposed by the ld. TPO. 3. Aggrieved with the order of TPO, assessee filed its objection before ld. DRP and the ld. DRP after considering

DCIT(It)-3(2)(2), Mumbai vs. Murex Southeast Asia Private Limited, Singapore

The appeal of the Revenue is dismissed

ITA 1453/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jun 2025AY 2014-15

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

Section 250Section 271(1)(c)

income for AY 2014-15 on 30.09.2015 declaring Nil income. The case was selected for scrutiny. The Assessing Officer (AO) passed a draft assessment order holding that the impugned receipts are taxable in India by treating the income from Software Sub-licensing as "Royalty" and income from Maintenance and Training ... page 141 to 143 of PB) rectifying the above order wherein he has deleted the addition which was not made in the draft assessment order but erroneously made in the final assessment order towards Sub- licensing receipts holding it as Royalty. We also notice that the Co-ordinate Bench while

Mr. 3 Sigma Global Fund, Mumbai vs. Assistant Commissioner of Income Tax Int Tax Circle 4(2)(1), Mumbai

Accordingly we hold that the gain arising from the transfer of Derivatives cannot be taxed in India and the addition made in this regard stands deleted. Ground No. 1 raised by the assessee is hereb...

ITA 1130/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Jun 2025AY 2022-23

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Bhaumik Goda, ARFor Respondent: Shri Krishna Kumar, Sr. DR

Section 143(3)

1119/Mum/2025 M/s Sigma Global Fund Derivatives and made additions in this regard while passing the draft assessment order. The assessee raised further objections before the DRP against the draft order of the assessee. The DRP held that the assessee is entitled for the treaty benefits and the relevant observations

Balram Chainrai, Mumbai vs. Int Tax Ward 2(1)(1), Mumbai

In the result, the appeal of the revenue bearing ITA No 519/Mum/2025 is dismissed

ITA 1074/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Jun 2025AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Ravikant S. Pathak, ARFor Respondent: 24.06.2025

Section 143(3)Section 144BSection 147Section 148Section 148ASection 153Section 234BSection 270ASection 69A

STCL of Rs. 73,05,006/- was not allowed to be set off. The assessee raised further objections before the DRP against the draft assessment order passed by the AO. The DRP confirmed the addition made by the AO by holding that “6.3.4 The applicant has asserted that there

Ashish Ashok Nirkhe, Mumbai vs. Income Tax Officer, Int Tax. Ward 3(3)(1), Mumbai

The appeal of the assessee is allowed

ITA 1005/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Jun 2025AY 2015-16

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Ms. Ushma Makecha, ARFor Respondent: Shri Krishna Kumar, Sr. DR

Section 143(3)Section 148Section 69Section 69A

dated 29.01.2025 for AY 2015-16. The assessee raised the following grounds of appeal: “1) The Learned DRP has erred in confirming the draft assessment order of Assessing Officer with making addition of Rs. 60,19,000/- on account of unexplained investment under section 69 of the Income

Edwards Lifesciences (India) Pvt Ltd, Mumbai vs. ACIT-2(1)(1), Mumbai

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

ITA 6188/MUM/2024[2021-22]Status: DisposedITAT Mumbai30 Jun 2025AY 2021-22

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailedwards Lifesciences (India) Pvt. Ltd., 4Th Floor Commerz – Ii, International Business Park Oberoi Garden City, Goregaon (East), Off Western Express Highway Goregaon (East), ............... Appellant Mumbai - 400063 Pan : Aaacb4203F V/S Assistant Commissioner Of Income Tax, Circle-2(1)(1), ……………… Respondent Kautilya Bhawan, Bkc, Mumbai - 400012 Assessee By : Ms. Chandni Shah Ms. Riddhi Maru Ms. Kinjal Patel Revenue By : Shri Bhagirath Ramawat, Sr.Dr

For Appellant: Ms. Chandni ShahFor Respondent: Shri Bhagirath Ramawat, Sr.DR

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 92B

expenses leading to creation of marketing intangible benefitting the Associated Enterprises at Rs.92,12,,742/-. 11. The Assessing Officer (“AO”), vide draft assessment order dated 20.11.2023 passed under section 144C(1) of the Act, computed the total income of the assessee at Rs.11,39,26,511/- after incorporating the Transfer

Marvelous Cement Private Limited, New Delhi vs. Income Tax Officer Ward 16(4), New Delhi

In the result, appeal filed by the assessee is allowed

ITA 4099/DEL/2024[2012-13]Status: DisposedITAT Delhi30 Jun 2025AY 2012-13

Bench: Ms.Madhumita Roy & Shri Manish Agarwal[Assessment Year : 2012-13] Marvellous Cement Pvt.Ltd., Vs Income Tax Officer, Flat No.305, 3Rd Floor, Ward-16(4), Bakshi House, 40-41 Nehru New Delhi Place, New Delhi-110019. Pan-Aaecm9931F Appellant Respondent [Assessment Year : 2018-19] Marvellous Cement Pvt.Ltd., Vs National E-Assessment Flat No.305, 3Rd Floor, Centre, New Delhi Bakshi House, 40-41 Nehru Place, New Delhi-110019. Pan-Aaecm9931F Appellant Respondent Appellant By Shri Ashwani Kumar, Ca & Shri Ankur Agarwal, Ca Respondent By Shri Virender Kumar Singh, Sr.Dr Date Of Hearing 05.05.2025 Date Of Pronouncement 30.06.2025 Order Per Manish Agarwal, Am : Both The Captioned Appeals Are Filed By The Assessee Against Two Separate Orders, Both Dated 22.07.2024 Passed By Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld.Cit(A)”] In Appeal No. Cit(A), Delhi- 6/10624/2019-20 & Appeal No. Nfac/2017-18/10022053 Respectively, Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”]. Both The Appeals Are Arising From The Assessment Orders, Dated 24.12.2019 U/S 143(3)/147 Of The Act & Dt. 15.09.2020

Section 139(1)Section 143(3)Section 147Section 148Section 250

justified to uphold the action of the Ld. Assessing Officer in passing the order without providing a copy of the draft assessment order to the Appellant despite a specific request made by it vide letter dated 04.09.2020 to the Ld. Assessing Officer, National e-Assessment Centre thus violating the principles

Jones Lang Lasalle Property Consultants (India) Private Limited, Delhi, India vs. Deputy Commissioner of Income Tax, Circle 13(1), Delhi, India

In the result, the appeal of the assessee is allowed and the Stay

ITA 3964/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jun 2025AY 2020-21

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2020-21 & Stay Application No.61/Del/2025 ( In Ita No. 3964/Del/2024 ) Assessment Year: 2020-21

For Appellant: S/Shri Nageshwar Rao and ParthFor Respondent: ShriDharam Veer Singh, CIT (DR)

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 144CSection 144C(12)Section 144C(13)Section 144C(5)Section 41Section 92

including order dated 30.05.2023 of Ld. TPO under Section 92 CA(3) wherein TP adjustment of Rs.296,90,11,730/- was determined vide draft assessment order dated 16.08.2023 by the Ld. AO. 4. Against draft assessment order dated 16.08.2023, assessee preferred Objections dated 13.09.2023 before the Dispute Resolution Panel ... time barred having been passed beyond the time limit prescribed under Section 144C(13) for completion of assessment. The draft assessment order under Section 144C(1) of the Act is dated 16.08.2023. Objections to draft assessment order filed on 14.09.2023 were decided on 31.05.2024 by DRP-2. Page

Essar Communications Limited, Mauritius vs. ACIT, Circle-1 (2)(2), New Delhi

ITA 340/DEL/2022[2012-13]Status: DisposedITAT Delhi30 Jun 2025AY 2012-13

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Percy Pardiwala, Sr. AdvocateFor Respondent: Shri N. Venkatraman, ASG

Section 250Section 253Section 6(3)

India and were not entitled to the benefit claimed under the tax treaty. Accordingly, long term capital gains were charged to tax. The draft assessment orders were issued and served on the assessees on 15.03.2021 u/s 144C of the Act. Vide letter dated 17.03.2021, the assessees informed the AO that

Essar Com Limited, Mauritius vs. ACIT, Circle 1(2)(2), New Delhi

ITA 339/DEL/2022[2012-13]Status: DisposedITAT Delhi30 Jun 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahman

For Appellant: Shri Percy Pardiwala, Sr. AdvocateFor Respondent: Shri N. Venkatraman, ASG

Section 250Section 253Section 6(3)

Rameshwaram Steel and Power Private Ltd., Chhattisgarh vs. DCIT, CC-20, Delhi

In the result, both the appeals of the appellant/assessee are allowed

ITA 1015/DEL/2021[2008-09]Status: DisposedITAT Delhi30 Jun 2025AY 2008-09

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2007-08 Assessment Year: 2008-09 Rameshwaram Steel & Vs The Deputy Power Private Ltd., . Commissioner Of Income 1, Village Bade Guma, Tax, Ghar Ghoda, Raigarh Central Circle-20, Chhattisgarh New Delhi Delhi- 496001 Pan No. Aaccr7462A (Appellant) (Respondent)

For Appellant: Shri Ved Jain, Adv. &For Respondent: Shri Dayainder Singh Sidhu

Section 132Section 142(1)Section 153ASection 153BSection 153CSection 153DSection 250

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 ... 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." [Emphasis supplied] 12. It is observed that the Court in the case of Sapna Gupta (supra

Rameshwaram Steel and Power Private Ltd., Chhattisgarh vs. DCIT, CC-20, New Delhi

In the result, both the appeals of the appellant/assessee are allowed

ITA 1014/DEL/2021[2007-08]Status: DisposedITAT Delhi30 Jun 2025AY 2007-08

For Appellant: Shri Ved Jain, Adv. &For Respondent: Shri Dayainder Singh Sidhu

Section 132Section 142(1)Section 153ASection 153BSection 153CSection 153DSection 250

Pandurang Daulatrao Korde, Nagpur vs. Income Tax Officer Ward 5(1), Nagpur

In the result, Assessee’s appeal is allowed

ITA 125/NAG/2025[2013-14]Status: DisposedITAT Nagpur27 Jun 2025AY 2013-14

Bench: Shri Narender Kumar Choudhrypandurang Daulatrao Korde, Ito, Ward-5(1), Nagpur Pande Layout, Khamla, Nagpur. Vs. Pan: Acmpk 9991 L (Appellant) (Respondent)

For Appellant: Shri Bhavesh Moriyani, Ld. AdvFor Respondent: Shri Surjit Kumar Saha, Ld. Sr.D.R

Section 143(2)Section 143(3)Section 147Section 148Section 250Section 292BSection 69

therefore the AO issued last show-cause notice dated 07/03/202, in response to which, the Assessee made compliance. Thereafter, the Ld. AO issued draft assessment order dated 15/03/2022 afforded opportunity to the Assessee, against which the Assessee filed its reply. Thereafter, the Ld. AO finally as per the facts available