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“eligible assessee”

Assessment ProceduresSection 144CSection 144C662 judgments

The decision most relied on for eligible assessee is CIT v. Smifs Securities Ltd. (348 ITR 302), cited in 540 judgments on BharatTax.

Leading authorities on eligible assessee

CIT v. Smifs Securities Ltd.
348 ITR 302 · 2012 · Supreme Court
540
citing judgments

Goodwill, whether arising from an amalgamation or a slump sale, is an intangible asset eligible for depreciation under Section 32(1) of the Income-tax Act. While the assessee must prove the existence and valuation of such goodwill, it is recognized as a depreciable asset.

Pandian Chemicals Ltd. v. CIT
262 ITR 278 · 2003 · Supreme Court
353
citing judgments

Income eligible for deduction under Section 80IA or 80IC must have a direct nexus with the eligible business activity of the industrial undertaking. Income merely incidental to the business, even if part of the assessee's overall business, is not considered "derived from" the eligible undertaking.

CIT v. Yokogawa India Ltd.
391 ITR 274 · 2017 · Supreme Court
290
citing judgments

Deduction under Section 10A or 10AA of the Income-tax Act is computed on the profits of the eligible unit without first setting off losses from other units or non-eligible units. Conversely, losses incurred by an eligible unit are allowed to be set off against the assessee's other taxable business profits.

CIT v. ABG Heavy Industries Ltd.
322 ITR 323 · 2010 · High Court
229
citing judgments

The Assessing Officer cannot deny a Section 80IA deduction by merely asserting that the assessee is not a "developer" without considering the relevant agreements and facts. Entitlement to Section 80IA deduction requires a thorough examination of the assessee's role as a developer.

CIT v. Claris Lifesciences Ltd.
326 ITR 251 · 2010 · High Court
196
citing judgments

If approval from the Department of Scientific and Industrial Research (DSIR) for an in-house R&D centre is granted during the previous year, the assessee is entitled to claim weighted deduction under section 35(2AB) for the entire expenditure incurred during that year.

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.

CIT v. Ramkrishna Deo
35 ITR 312 · 1959 · Supreme Court
84
citing judgments

The burden of proving that a particular income is exempt from taxation, or is not taxable, lies on the assessee. To claim an exemption or a deduction, the assessee must provide proper materials to establish eligibility.

CIT v. Kamal Wahal
351 ITR 4 · 2013 · High Court
71
citing judgments

An assessee is eligible for capital gains exemption under Sections 54 and 54F even when the new residential house is purchased in the name of their spouse, provided the investment comes from the assessee's own funds. This allows for a purposive construction of these provisions.

Judgments citing eligible assessee

DCIT-3(4), Mumbai vs. M/S. Ambuja Cements Ltd., Mumbai

In the result, appeals of the revenue and CO’s of assessee stands dismissed

ITA 2031/MUM/2023[2008-09]Status: DisposedITAT Mumbai11 Dec 2023AY 2008-09

Bench: Shri Aby T. Varkey, Jm & Shri Prashant Maharishi, Am आयकर अपील सं/ I.T.A. No.2031/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2008-09) Dcit-3(4) बिधम/ M/S. Ambuja Cements Ltd 29Th Floor, Center-1, World 3Rd Floor, Elegant Vs. Trade Center, Cuffe Parade, Business Park, Midc Mumbai-400005. Cross, Road B Andheri East, Mumbai-400059. Cross Objection No. 90/Mum/2023 Arising Out Of I.T.A. No.2031/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2008-09) M/S. Ambuja Cements Ltd बिधम/ Dcit-3(4) 3Rd Floor, Elegant Business 29Th Floor, Center-1, Vs. Park, Midc Cross, Road B World Trade Center, Andheri East, Mumbai- Cuffe Parade, Mumbai- 400059. 400005. आयकर अपील सं/ I.T.A. No.2032/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) Dcit-3(4) बिधम/ M/S. Ambuja Cements Ltd 29Th Floor, Center-1, World 3Rd Floor, Elegant Vs. Trade Center, Cuffe Parade, Business Park, Midc Mumbai-400005. Cross, Road B Andheri . East, Mumbai-400059. Cross Objection No. 91/Mum/2023 Arising Out Of I.T.A. No.2032/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) M/S. Ambuja Cements Ltd बिधम/ Dcit-3(4) 3Rd Floor, Elegant Business 29Th Floor, Center-1, Vs. Park, Midc Cross, Road B World Trade Center, Andheri East, Mumbai- Cuffe Parade, Mumbai- 400059. 400005. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaacg0569P (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: None Revenue By: Shri Ajay Chandra (Dr) C.O. 90 & 91/Mum/2023 A.Ys. 2008-09 & 2010-11 Ambuja Cements Ltd सुनवाई की तारीख / Date Of Hearing: 11/10/2023 घोषणा की तारीख /Date Of Pronouncement: 11/12/2023 आदेश / O R D E R Per Bench: These Are Appeals Preferred By The Revenue & Respective Cross Objections (‘Co’) Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [In Short ‘Ld. Cit(A)’] Dated 31-03-2023 For Ay 2008-09 & Ay 2010-11 Respectively.

For Appellant: NoneFor Respondent: Shri Ajay Chandra (DR)
Section 115Section 115JSection 143(3)Section 80I

what is the "initial assessment year". Prior to 1-4-2000, section 80IA(12) defined the "initial assessment year" for various types of eligible assessees. However, after the amendment by the Finance Act, 1999, the definition of "initial assessment year" has been specifically taken away. Now, when the assessee exercises

Gunita Pradeep Kapur, Mumbai vs. ITO, Ward-19(1)(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 1989/MUM/2023[2016-17]Status: DisposedITAT Mumbai06 Nov 2023AY 2016-17

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyalgunita Pradeep Kapur 4Th Floor, Mitra Kunj, 16 Peddar Road, Grant Road, Mumbai-400 026 Pan: Aivpk6313M ...... Appellant Vs. Ito Ward 19(1)(3) Matru Mandir, Tardeo Road, Mumbai-400007 ..... Respondent

For Appellant: Shri K. Gopal & Om Kandalkar, Ld. ARFor Respondent: Shri Rameshwar Meena, Ld. DR
Section 250Section 44A

gains of business on presumptive basis. 44AD. (1) Notwithstanding anything to the contrary contained in sections 28 to 43C, in the case of an eligible assessee engaged in an eligible business, a sum equal to eight per cent of the total turnover or gross receipts of the assessee ... account of such business or, as the case may be, a sum higher than the aforesaid sum claimed to have been earned by the eligible assessee, shall be deemed to be the profits and gains of such business chargeable to tax under the head "Profits and gains of business

The ACIT Corporate, Cochin vs. M/S.Kera Fibertex International P. Ltd, Cochin

In the result, the appeals by the assessee is allowed, and that by the Revenue, dismissed

ITA 361/COCH/2015[2009-10]Status: DisposedITAT Cochin30 Oct 2023AY 2009-10

Bench: Shri Sanjay Arora (Accountant Member), Shri Manomohan Das (Judicial Member)

For Appellant: Shri P. Sathisan, AdvocateFor Respondent: Shri Sajit Kumar Das, CIT-DR
Section 143(3)Section 144CSection 144C(2)Section 153Section 153B

first instance, forward a draft of the proposed order of assessment (hereafter in this section referred to as the draft order) to the eligible assessee if he proposes to make, on or after the 1st day of October, 2009, any variation which is prejudicial to the interest of such assessee ... receipt of the draft order, the eligible assessee shall, within thirty days of the receipt by him of the draft order,— (a) file his acceptance of the variations to the Assessing Officer; or (b) file his objections, if any, to such variation with,— (i) the Dispute Resolution Panel

M/S.Kera Fibertex International P. Ltd, Cochin vs. The ACIT, Cochin

In the result, the appeals by the assessee is allowed, and that by the Revenue, dismissed

ITA 311/COCH/2015[2009-10]Status: DisposedITAT Cochin30 Oct 2023AY 2009-10

Bench: Shri Sanjay Arora (Accountant Member), Shri Manomohan Das (Judicial Member)

For Appellant: Shri P. Sathisan, AdvocateFor Respondent: Shri Sajit Kumar Das, CIT-DR
Section 143(3)Section 144CSection 144C(2)Section 153Section 153B

first instance, forward a draft of the proposed order of assessment (hereafter in this section referred to as the draft order) to the eligible assessee if he proposes to make, on or after the 1st day of October, 2009, any variation which is prejudicial to the interest of such assessee ... receipt of the draft order, the eligible assessee shall, within thirty days of the receipt by him of the draft order,— (a) file his acceptance of the variations to the Assessing Officer; or (b) file his objections, if any, to such variation with,— (i) the Dispute Resolution Panel

Bijender Singh Thakran, Gurgaon vs. ITO, Ward-1(3), Gurgaon

In the result, appeal of assessee is partly allowed

ITA 2017/DEL/2023[2011-12]Status: DisposedITAT Delhi18 Oct 2023AY 2011-12

Bench: The Disposal Of The Appeal.” Ground No. 1 & 2:

Section 143(3)Section 2(14)Section 4Section 44ASection 69A

/147 is being challenged on facts & law. 2. (a) Because the action of treating the whole turnover of Rs.8,25,000/- of the ‘eligible assessee engaged in an eligible business’ as unexplained income u/s 69A is in violation to due process of law and against I.T.A.No.2017/Del/2023 intent/rationale behind section

Defsys Solutions P.Ltd, New Delhi vs. ACIT, Central Circle-15, New Delhi

In the result the appeal of the assessee in ITA No

ITA 1818/DEL/2023[2020-21]Status: DisposedITAT Delhi17 Oct 2023AY 2020-21

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Rajesh Kumar, CIT-DR
Section 143(3)Section 144CSection 144C(13)Section 156Section 271ASection 274

first instance, forward a draft of the proposed order of assessment (hereafter in this section referred to as the draft order) to the eligible assessee if he proposes to make, on or after the 1st day of October, 2009, any variation in the income or loss returned which is prejudicial ... 144C of the Act is of great importance and is mandatory. Before the Assessing Officer can make variations in the returned income of an eligible assessee, as noted, sub-section (1) of Section 144C lays down the procedure to be followed notwithstanding anything to the contrary contained

Guala Closures (India) Pvt. Ltd., Panaji vs. The Principal Commissioner of Income Tax, Panaji., Select City

Appeal is dismissed in above terms

ITA 205/PAN/2019[2012-13]Status: DisposedITAT Panaji13 Oct 2023AY 2012-13

Bench: Shri Satbeer Singh Godara & Dr. Dipak Ripote

For Appellant: Shri Ketan VedFor Respondent: Shri P.S. Shivshankar, CIT-DR
Section 143(3)Section 144(3)Section 144CSection 253Section 263Section 4

first instance, forward a draft of the proposed order of assessment (hereafter in this section referred to as the draft order) to the eligible assessee if he proposes to make, on or after the 1st day of October, 2009, 15 ITA.No.205/PAN./2019 any variation in the income or loss ... returned which is prejudicial to the interest of such assessee. (2) On receipt of the draft order, the eligible assessee shall, within thirty days of the receipt by him of the draft order,- (b) file his acceptance of the variations to the Assessing Officer; or (b) file his objections

ACIT Circle -2(1)(1) - International Taxation, New Delhi vs. Innways Venture Ltd, New Delhi

In the result, the appeal of the Revenue in ITA No

ITA 92/DEL/2020[2015-16]Status: DisposedITAT Delhi11 Oct 2023AY 2015-16

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri Ravi Sharma, AdvFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 144CSection 144C(1)Section 144C(13)

7076/MUM/2018. Pertinent findings of the co-ordinate bench are given as under: “11. In the instant case, the assessee herein is an eligible assessee. However, there is no variation in the income or loss returned, which is prejudicial to the interests of the assessee. Hence the second condition prescribed ... first instance, forward5 a draft of the proposed order of assessment (hereafter in this section referred to as the draft order) to the eligible assessee if he proposes to make, on or after the 1st day of October, 2009, any variation in the income or loss returned which is prejudicial

Indium IV (Mauritius) Holdings Limited, Mumbai vs. Deputy Comm. of Income Tax (International Taxation) 2(2)(1), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 2423/MUM/2022[2017-18]Status: DisposedITAT Mumbai06 Oct 2023AY 2017-18

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleindium Iv (Mauritius) Holdings Limited V. Dcit (International Transaction)-2(2)(1) Office 201, 2Nd Floor, Sterling Tower Room No. 1722, 17Th Floor Air India Building, Nariman Point 14 Poudriere Street, Port Louis Mumbai – 400 021 Mauritius Pan: Aacci4907P (Appellant) (Respondent)

Section 143(2)Section 144C(5)Section 2(24)Section 45Section 92C

thoughtful consideration to the submissions. The Panel notes that section 144C is a complete code in itself and is applicable in the case of eligible assessee as defined in section. 144C(15)(b). Section 144C(1), as it stood for AY 2017-18, provides that the Assessing Officer shall, notwithstanding ... anything to the contrary contained in this Act in the first instance, forward a draft of the proposed order of assessment to the eligible assessee if he proposes to make any variation in the income or loss returned which is prejudicial to the interest of such assessee. Thus

Jaguar Land Rover India Ltd., Mumbai vs. Addl/Jt./Dy/CIT/Asstt/ITO, National E-Assessment Centre, Delhi

In the result, appeal of the assessee is allowed

ITA 1222/MUM/2021[2016-17]Status: DisposedITAT Mumbai06 Oct 2023AY 2016-17
Section 143(2)Section 143(3)Section 40Section 40aSection 92C

compilation was filed before us. He further submitted that once the ld. TPO order is barred by limitation, then assessee is no longer an eligible assessee and therefore, there was no requirement for passing draft assessment order and accordingly, final assessment order should have been passed on or before 31/12/2019 ... order) under section 92CA(3) of the Act is passed. 10. Last date to pass final 31.12.2019 assessment order considering assessee is not an eligible assessee 11. Date on which final assessment 23.04.2021 order was passed 6 M/s. Jaguar Land Rover India Ltd. 6. Before us, ld. DR submitted that

Urmila Tank, Jaipur vs. Income Tax Officer, Ward 5(2), Jaipur

In the result, appeal of the assessee is partly allowed

ITA 259/JPR/2023[2016-17]Status: DisposedITAT Jaipur26 Sept 2023AY 2016-17

Bench: The Tribunal On 22.04.2023 Within The Time Limit. The Due Date Of Filing

For Appellant: Shri Rahul Chatter, AdvocateFor Respondent: Ms Monisha Choudhary (JCIT)
Section 1Section 44A

Section 44AD of the Income Tax Act: “Notwithstanding anything to the contrary contained in sections 28 to 43C, in the case of an eligible assessee engaged in an eligible business, a sum equal to eight per cent of the total turnover or gross receipts of the assessee in the previous ... account of such business or, as the case may be, a sum higher than the aforesaid sum claimed to have been earned by the eligible assessee, shall be deemed to be the profits and gains of such business chargeable to tax under the head "Profits and gains of business

Little Fairy Limited, Nicosia vs. ACIT, Circle Int. Tax. 2(2)(1), Delhi

In the result both the appeals of the assessee are allowed as indicated above

ITA 1512/DEL/2022[2016-17]Status: DisposedITAT Delhi25 Sept 2023AY 2016-17

Bench: Shri G. S. Pannua N D Shri Challa Nagendra Prasad

For Appellant: Shri G. C. Srivastava

shall in the first instance forward a draft of the proposed order of assessment (draft order') to the eligible assessee, if he proposes to make any variation in the income or loss returned, which is prejudicial to the interest of the assessee. ii) As per Section 144C ... Eligible Assessee' means - (a) Any person in whose case variation referred to in Section 144C(1) of the Act arises as a consequence of the order of the TPO passed under 92CA(3) of the Act; and (b) Any foreign company. iii) Therefore, for passing a draft order under Section

Little Fairy Ltd, Nicosia vs. ACIT, Circle 2(2)(1), International Taxation, New Delhi

In the result both the appeals of the assessee are allowed as indicated above

ITA 1511/DEL/2022[2015-16]Status: DisposedITAT Delhi25 Sept 2023AY 2015-16

Bench: Shri G. S. Pannua N D Shri Challa Nagendra Prasad

For Appellant: Shri G. C. Srivastava

shall in the first instance forward a draft of the proposed order of assessment (draft order') to the eligible assessee, if he proposes to make any variation in the income or loss returned, which is prejudicial to the interest of the assessee. ii) As per Section 144C ... Eligible Assessee' means - (a) Any person in whose case variation referred to in Section 144C(1) of the Act arises as a consequence of the order of the TPO passed under 92CA(3) of the Act; and (b) Any foreign company. iii) Therefore, for passing a draft order under Section

Gammon India Ltd, Mumbai vs. DCIT, CC- 7(2)., Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 1440/MUM/2020[2010-11]Status: DisposedITAT Mumbai22 Sept 2023AY 2010-11

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Rahul Chaudhary, Hon'Blem/S. Gammon India Ltd V. Dcit-Central Circle 7(2) 3Rd Floor, Plot No. 3/8 Room No. 655, 6Th Floor Hamilton House, J.N. Heredia Marg Aayakar Bhavan Ballard Estate, Mumbai- 400038 M.K. Road, Mumbai- 400020 Pan: Aaacg3821A (Appellant) (Respondent) Dcit, Central Circle 7(2) V. M/S. Gammon India Ltd Room No. 655, 6Th Floor 1, Gammon House Aayakar Bhavan, M.K. Road Veer Savarkar Marg Mumbai- 400020 Prabhadevi, Mumbai - 400025 Pan: Aaacg3821A (Appellant) (Respondent)

Section 92B(1)

passing the TPO order is declared as time barred, then it does not mean that assessee does not qualify as 'eligible assessee' and in TPO's Page No. | 4 ITA NO. 2990/MUM/2019 (A.Y: 2010-11) M/s. Gammon India Ltd order there was a clear cut variation as consequence ... order of TPO. Here in this case, TPO had proposed TP adjustment and therefore, assessee was clearly 'eligible assessee' u/s 144C (1) r.w.s. Clause (b) of sub-section (15) of section 144C. At the most, only the TP addition may not be considered but other corporate addition will be sustained

DCIT CC 7(2), Mumbai vs. M/S Gammon India Ltd., Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 2990/MUM/2019[2010-11]Status: DisposedITAT Mumbai22 Sept 2023AY 2010-11

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Rahul Chaudhary, Hon'Blem/S. Gammon India Ltd V. Dcit-Central Circle 7(2) 3Rd Floor, Plot No. 3/8 Room No. 655, 6Th Floor Hamilton House, J.N. Heredia Marg Aayakar Bhavan Ballard Estate, Mumbai- 400038 M.K. Road, Mumbai- 400020 Pan: Aaacg3821A (Appellant) (Respondent) Dcit, Central Circle 7(2) V. M/S. Gammon India Ltd Room No. 655, 6Th Floor 1, Gammon House Aayakar Bhavan, M.K. Road Veer Savarkar Marg Mumbai- 400020 Prabhadevi, Mumbai - 400025 Pan: Aaacg3821A (Appellant) (Respondent)

Section 92B(1)

passing the TPO order is declared as time barred, then it does not mean that assessee does not qualify as 'eligible assessee' and in TPO's Page No. | 4 ITA NO. 2990/MUM/2019 (A.Y: 2010-11) M/s. Gammon India Ltd order there was a clear cut variation as consequence ... order of TPO. Here in this case, TPO had proposed TP adjustment and therefore, assessee was clearly 'eligible assessee' u/s 144C (1) r.w.s. Clause (b) of sub-section (15) of section 144C. At the most, only the TP addition may not be considered but other corporate addition will be sustained

M/S. Kandla Energy and Chemicals Ltd., Village Devaliya, Tal. Anjar(Kutch) vs. Add. CIT, Gandhidham Range, Gandhidham(Kutch)

In the result, the appeal filed by the Assessee is hereby dismissed

ITA 399/RJT/2018[2014-15]Status: DisposedITAT Rajkot15 Sept 2023AY 2014-15

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 143(3)Section 144C(1)Section 144C(2)Section 144C(2)(b)Section 144C(3)Section 40A(2)(b)Section 92CSection 92E

first instance, forward a draft of the proposed order of assessment (hereafter in this section referred to as the draft order) to the eligible assessee if he proposes to make, on or after the 1st day of October, 2009, any variation in the income or loss returned which is prejudicial ... interest of such assessee. (2) On receipt of the draft order, the eligible assessee shall, within thirty days of the receipt by him of the draft order,- (a) file his acceptance of the variations to the Assessing Officer ; or (b) file his objections, if any, to such variation with

Subhash Chand Saini, Jaipur vs. ITO Ward, Behror

In the result the appeal of the assessee is allowed

ITA 230/JPR/2023[2017-2018]Status: DisposedITAT Jaipur12 Sept 2023AY 2017-2018

Bench: Or At The Time Of Hearing Of Appeal.”

For Appellant: Shri P. K. Garg (C.A.)For Respondent: Smt Monisha Choudhary (Addl. CIT) a
Section 142(1)Section 143(2)Section 271BSection 275Section 44A

44AD of Income Tax Act, 1961, (1) Notwithstanding anything to the contrary contained in sections 28 to 43C, in the case of an eligible assessee engaged in an eligible business, a sum equal to eight per cent of the total turnover or gross receipts of the assessee in the previous ... account of such business or, as the case may be, a sum higher than the aforesaid sum claimed to have been earned by the eligible assessee, shall be deemed to be the profits and gains of such business chargeable to tax under the head "Profits and gains of business

Intergreon Munaged Solutions (India) P.Ltd, Mumbai vs. Asst CIT 12(2)(2), Mumbai

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

ITA 586/MUM/2015[2010-11]Status: DisposedITAT Mumbai07 Sept 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Ketan Ved
Section 250Section 92D

provision of section 144C of the Act, it is evident that the A.O. has to first forward a draft assessment order to the eligible assessee in case where he proposes to make any variation to the assessed income of the assessee for which the assessee shall within 30 days

Integreon Managed Solutions (India) P. Ltd, Mumbai vs. ITO 8(2)(1), Mumbai

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

ITA 2307/MUM/2012[2007-08]Status: DisposedITAT Mumbai07 Sept 2023AY 2007-08

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Ketan Ved
Section 250Section 92D

provision of section 144C of the Act, it is evident that the A.O. has to first forward a draft assessment order to the eligible assessee in case where he proposes to make any variation to the assessed income of the assessee for which the assessee shall within 30 days

ITO 8(2)(1), Mumbai vs. Integreon Managed Solution (I) P. Ltd, Mumbai

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

ITA 2095/MUM/2012[2007-08]Status: DisposedITAT Mumbai07 Sept 2023AY 2007-08

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Ketan Ved
Section 250Section 92D

provision of section 144C of the Act, it is evident that the A.O. has to first forward a draft assessment order to the eligible assessee in case where he proposes to make any variation to the assessed income of the assessee for which the assessee shall within 30 days