“protective assessment”

MiscellaneousAssessmentAssessment441 judgments

The decision most relied on for protective assessment is Lalji Haridas v. ITO (43 ITR 387), cited in 238 judgments on BharatTax.

Leading authorities on protective assessment

Lalji Haridas v. ITO

43 ITR 387 · 1961 · Supreme Court

238

citing judgments

When an assessing authority is uncertain about the true ownership of funds or in whose hands income should be assessed, it can frame a protective assessment to safeguard the Revenue's interest. Such protective assessments remain valid until the substantive assessment is finalized.

CIT, Gujarat II v. Surendra Gulab Chand Modi

140 ITR 517 · 1983 · High Court

citing judgments

Protective assessments should not be deleted or disposed of by lower authorities, but rather allowed to remain in effect until the related substantive assessment proceedings attain finality before the High Court or Supreme Court.

DHFL Venture Capital Fund v. ITO

358 ITR 471 · 2013 · High Court

citing judgments

Reassessment proceedings cannot be initiated solely for the purpose of making a protective addition. Such proceedings are not valid in the eyes of law.

Bhailal Manilal Patel v. CIT

49 Taxmann.com 539 · 2014 · High Court

citing judgments

Penalty under section 271(1)(c) cannot be imposed based on a protective assessment order. Initiation of penalty proceedings is impermissible without a substantive assessment order that finally adds income to the assessee's hands.

Peter Vaz v. Commissioner of Income Tax, Central Circle, Bangalore

128 Taxmann.com 180 · 2021 · High Court

citing judgments

An assessee can raise an objection regarding the validity of the Assessing Officer's jurisdiction for reopening a concluded assessment even if the issue was not raised before the CIT(Appeals), by invoking Rule 27 of the Income Tax Appellate Tribunal Rules, 1963. This is permissible if the issue is ancillary to the main issue and does not require additional evidence.

(CIT v. Cochin Co. Pvt. Ltd.

104 ITR 655 · 1976 · High Court

citing judgments

A protective assessment is permissible when the assessing officer has doubt regarding who is in receipt of income, but a recovery based on a protective assessment is not allowed. If an assessment is intended to be protective, it must be clearly stated as such.

CIT v. Super Steel (Sales) Co.

178 ITR 451 · 1989 · High Court

citing judgments

A penalty under Section 271(1)(c) for concealment of income cannot be levied when the assessment was made on a protective basis, especially if the income was actually assessed in the hands of another person and it was uncertain who had concealed the income.

Suresh K. Jajoo v. ACIT

39 SOT 514 · 2010 · ITAT

citing judgments

A protective assessment cannot be made without a prior substantive assessment.

Judgments citing protective assessment

Deputy Commissioner of Income Tax, Delhi vs. Ravi Bharadwaj, Delhi

In the result, the appeal filed by the Revenue for the AY 2013-14 is dismissed

ITA 2230/DEL/2025[2011-12]Status: DisposedITAT Delhi21 Jan 2026AY 2011-12

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri V.K. Agarwal, AdvocateFor Respondent: Shri Jitender Singh, CIT DR

Section 132Section 142(1)Section 143

hold accordingly. Hence, the said additions made by the AO are hereby deleted. 16. The appellant has further submitted that the AO has made protective assessment on the ground that the proceedings are pending under the BMA. Since the information was received from BVI in respect of Undisclosed Foreign Assets ... additions have subsequently been made u/s 10(3) of the BMA for AY 2017- 18. This is the contention of the appellant that the protective assessment has been made prior to substantive assessment under the BMA which is an illegality. It has been contended that it is judicially settled that

Radhika Jewellers, Rajkot vs. Dy.CIT 2 (1), Rajkot

In the result, appeal filed by the assessee is allowed

ITA 568/RJT/2025[2015-16]Status: DisposedITAT Rajkot20 Jan 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri Samir Jani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 142(1)Section 143(2)Section 143(3)Section 250Section 45Section 45(3)

additions, so made by the assessing officer, in the hands of the assessee firm, needs to be deleted. 15. When can and why a protective assessment be made. An assessment which is made to protect the interests of revenue against the bar of limitation is called 'protective assessment, it also ... situation, he may assess the income in the hands of either A or B and at the same time, he may make a protective assessment on B or A, as the case may be. The protective assessment is kept as a stand by and it will spring into action only

Sael Limited, Faridkot Road Guruharsahai vs. DCIT, CC-1, Ludhiana

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

ITA 704/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh14 Jan 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashray Sarna, C.AFor Respondent: Shri Rajat Kumar Kureel, CIT, DR

Section 143(3)

very nature, is not a conclusive determination of income and was only made to safeguard the revenue interest in an uncertain situation. Such a protective assessment cannot form the basis for denying legitimate carry forward and set off of business losses. The CIT(A) further failed to appreciate that

Pooja Prabhakar, Chennai vs. Income Tax Officer, Non Corporate Ward 15(1), Chennai

ITA 3048/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Jan 2026AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:3046, 3047 & 3048/Chny/2025 निर्धारण वर्ष / Assessment Years: 2015-16, 2016-17 & 2017-18 Pooja Prabhakar, 17 Kingston Apartments, M G Ramachandran Road Kalakshetra Colony, Chennai - 600 090. [Pan: Bcgpp-8061-H] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By Ito, Vs. Non-Corp Ward -15(1), Chennai. (प्रत्यर्थी/Respondent) : Mr. R. Venkataraman, Fca & Mr. K. Vishwa Padmanabhan, Fca. : Shri. Arv Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement आदेश /Order Per S. R. Raghunatha, Am : : 16.12.2025 : 01.01.2026 These Three Appeals Preferred By The Assessee Are Directed Against The Separate Orders, Each Dated 25.08.2025, Passed By The Learned Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred To As “Ld. Cit(A)”). The Impugned Orders Arise Out Of The Assessments Framed By The National Faceless Assessment Centre (Hereinafter Referred To As The "Ao”) U/S.147 R.W.S 144 Of The Income-Tax Act, 1961 (Hereinafter Referred To As "The Act"), Pertaining To Assessment Years 2015-16, 2016-17 & 2017-18 :-2-:

Section 144Section 147Section 148Section 148ASection 201Section 69A

said proceedings, it was noticed that various credits had been recorded in the bank account of the assessee, which, according to the Department, required protective assessment in her hands. 7. Consequent thereto, a notice u/s.148 of the Act dated 31.03.2021, digitally signed on 01.04.2021, was issued by the Jurisdictional Assessing

Pooja Prabhakar, Chennai vs. Income Tax Officer, Non Corporate Ward 15(1), Chennai

In the result, all the three appeals of the assessee for the A

ITA 3047/CHNY/2025[2016-17]Status: DisposedITAT Chennai01 Jan 2026AY 2016-17

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Mr. R. Venkataraman, FCA &For Respondent: Shri. ARV Sreenivasan, CIT

Section 144Section 147Section 148Section 148ASection 201Section 69A

Pooja Prabhakar, Chennai vs. Income Tax Officer, Non Corporate Ward 15(1), Chennai

ITA 3046/CHNY/2025[2015-16]Status: DisposedITAT Chennai01 Jan 2026AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:3046, 3047 & 3048/Chny/2025 निर्धारण वर्ष / Assessment Years: 2015-16, 2016-17 & 2017-18 Pooja Prabhakar, 17 Kingston Apartments, M G Ramachandran Road Kalakshetra Colony, Chennai - 600 090. [Pan: Bcgpp-8061-H] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By Ito, Vs. Non-Corp Ward -15(1), Chennai. (प्रत्यर्थी/Respondent) : Mr. R. Venkataraman, Fca & Mr. K. Vishwa Padmanabhan, Fca. प्रत्यर्थी की ओर से/Respondent By : Shri. Arv Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing : 16.12.2025 घोषणा की तारीख/Date Of Pronouncement : 01.01.2026 आदेश /Order Per S. R. Raghunatha, Am : These Three Appeals Preferred By The Assessee Are Directed Against The Separate Orders, Each Dated 25.08.2025, Passed By The Learned Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred To As “Ld. Cit(A)”). The Impugned Orders Arise Out Of The Assessments Framed By The National Faceless Assessment Centre (Hereinafter Referred To As The "Ao”) U/S.147 R.W.S 144 Of The Income-Tax Act, 1961 (Hereinafter Referred To As "The Act"), Pertaining To Assessment Years 2015-16, 2016-17 & 2017-18 :-2-:

For Respondent: Shri. ARV Sreenivasan, CIT

Section 144Section 147Section 148Section 148ASection 69A

DCIT Central Circle-32, New Delhi vs. Vikram Kumar Bajaj, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 1737/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Dec 2025AY 2017-18

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Mahesh Kumar, CIT(DR)

Section 131Section 153A

Court in the case of CIT, Gujarat II Vs. Surendra Gulab Chand Modi 140 ITR 517 (Guj) 1983 wherein it is held that such ‘Protective Assessment’- which in law should be allowed to remain as such – till the matters attain finality by Superior Courts- High Court or Hon’ble Supreme ... Allahabad Bench held that an appellate authority cannot evade the determination of who the real owner of the income is, even in cases of protective assessment. Since the substantive assessment in the case of Mr. Ram Narayan Bajaj has been quashed, the protective addition in the hands of the assessee

Amit Jain, Muzaffarnagar vs. Income Tax Officer, Ward - 3(1)(1), Muzaffarnagar

In the result, appeal of the assessee is allowed

ITA 4472/DEL/2025[2011-12]Status: DisposedITAT Delhi18 Dec 2025AY 2011-12

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.4472/Del/2025 िनधा"रणवष"/Assessment Year: 2011-12 बनाम Shri Amit Jain, Income Tax Officer, 640, Sanjay Marg, Vs. Ward 3(1)(1), Meerut Road, Patel Nagar, Muzafarnagar. Muzaffarnagar. Pan No.Afcpj7324P अपीलाथ" Appellant ""यथ"/Respondent

Section 250

have considered the rival submissions and have gone through the documents before us. It is a settled position that there cannot be a protective assessment without any substantive assessment elsewhere. In this case, after going through the documents before us and the fact that the Ld. DR has not been

Rajendra Kumar Shrivastava, Durg vs. ITO, NFAC, Delhi

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

ITA 744/RPR/2025[2020-21]Status: DisposedITAT Raipur12 Dec 2025AY 2020-21

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.744/Rpr/2025 "नधा"रण वष" /Assessment Year : 2020-21 Rajendra Kumar Shrivastava, Mig-42, Padmanabhpur, Durg (C.G.)-491 001 Pan: Alops3921M

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 139(1)Section 154Section 154(2)(B)Section 154(8)Section 155Section 186Section 36Section 36(1)(va)

action under section 154, or to admit or dispose of on merits applications under section 154 filed by assessees seeking relief, for cancelling such protective assessments as have become redundant by waiving, if necessary, the time limit fixed under sub-section (7) of section 154.-Circular: No. 71, dated

Madhushree Enterprises, Kampli, Hospet vs. DCIT, Bengaluru

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

ITA 697/BANG/2024[2011-12]Status: DisposedITAT Bangalore11 Dec 2025AY 2011-12

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2011-12

For Appellant: NoneFor Respondent: Shri Muthu Shankar, CIT-DR

Section 142(1)Section 143(2)Section 144Section 148Section 276CSection 37(1)Section 41(1)

assessee as the turnover of the said Shri Janardhana Reddy and assessment was made in his hands on substantial basis. The AO had made protective assessment on the assessee and not granted the expenditure incurred for earning the above income Page 3 of 7 since the entire activity

Sri Siba Shankar Das(Decezased) Through Legal Heir Smt. Ritanjali Das, Kalahandi vs. Deputy Commissioner of Income Tax, Circle-2(1), Sambalpur

In the result, appeal of the assessee is allowed

ITA 373/CTK/2025[2015-16]Status: DisposedITAT Cuttack02 Dec 2025AY 2015-16

For Appellant: Shri P.R. Mohanty, ARFor Respondent: Shri Vijay Singh, Sr. DR

Agarwal. It was the submission that in the assessment of Shri Banti Kumar Agarwal also the AO has treated the said amount as a protective assessment on account of the fact that Shri Banti Kumar Agarwal has shown the amount as an advance received from the assessee

ACIT, Chennai vs. Rajagopalan, Chennai

In the result, the appeal of the revenue is dismissed

ITA 1443/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Dec 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Ms. E. Pavuna Sundari, CIT

Section 132Section 132(4)Section 143(3)Section 245D(4)Section 250Section 69

cash deposits in the bank account is deleted and the ground raised by the appellant is allowed. 16. The Department accepted that the protective assessment does not subsist when the appeal in respect of the substantive assessment is adjudicated. However, on the issue of accepting the source of cash deposited

Suresh Kumar Kejriwal, La Gardina App. Shree Nagar, Indore vs. Income Tax Officer, Aaykar Bhawan, White Church Road, Indore

ITA 266/IND/2025[2012-13]Status: DisposedITAT Indore27 Nov 2025AY 2012-13

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

Section 144

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

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. V N S Finance, Karur

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

ITA 2292/CHNY/2024[2020-21]Status: DisposedITAT Chennai25 Nov 2025AY 2020-21

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Ms. Pushpa Hemachand, J.C.I.TFor Respondent: Shri. N. Arjun Raj, Advocate

Section 131Section 132Section 143(2)Section 143(3)

Rs.92,80,220/- in hands of Shri.K.Natrayan for the Asst.Year 2019-20 was deleted by the Ld.CIT(A) and not by deleting the protective assessment in the present case of M/s.VNS Finance, the Ld.CIT(A) has failed to appreciate the fact that the entire undisclosed cash found of Rs.92 ... well-settled legal position, supported by various judicial precedents, is that the same income cannot be assessed substantively in more than one hand. A protective assessment may continue to remain operative only until the substantive assessment reaches finality in the correct and appropriate hands. We further observe that the subsequent

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Ramasamy Rajasehar, Perambalur

In the result, appeal filed by the Revenue is dismissed and the Cross-Objection filed by the assessee is partly allowed

ITA 3336/CHNY/2024[2014-15]Status: DisposedITAT Chennai20 Nov 2025AY 2014-15

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Mr. Shiva Srinivas, C.I.T

Section 143(3)Section 69

that there being no substantive addition made in the case of the companies M/s. VASAN CONSTRUCTIONS COMPANY & M/s. DS BUILDERS, there could be no protective assessment in the case of the Assessee. 1.5 The CIT(A) rightly deleted the addition on the ground that the impugned addition tantamount to double ... Dhanalakshmi Srinivasan Group on 15.02.2018, the appellant’s residence was also subjected to search. Consequent to findings of the search the AO, framed a Protective Assessment Order in the case of the appellant. The appellant in his submission relies upon the sworn statements from Shri S. Kathiravan, the Vice Chairman

Sony India Private Limited, Delhi vs. ACIT Circle 22(2), Delhi

In the result, appeal filed by the assessee is partly allowed as indicated above

ITA 3851/DEL/2024[AY 2020-21]Status: DisposedITAT Delhi12 Nov 2025

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Roysony India Private Limited, Vs. Acit, Circle 22 (2), A – 18, Mohan Cooperative Indl. Area, New Delhi. Mathura Road, New Delhi – 110 044. (Pan :Aabcs1571Q) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 23.09.2025 Date Of Order : 12.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appealpreferred By The Assesseeis Directed Against The Assessment Order Dated 30.07.2024Passed By The Assessment Unit, Income Tax Department Under Section 143(3) Read With Section 144C(13) R.W.S. 144Bof The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020- 21Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :-

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR

Section 143(3)Section 144C(13)Section 144C(5)

Development functions ("MMDF") based on Bright Line Test ("BLT") approach In law and facts of present case: 4 15. Impugned order errs in retaining protective assessment based on BLT Contrary to Hon'ble jurisdiction High Court decision. Further such adjustment is based on incorrect presumptions and ignores relevant factors laid

Surendra Kumar Jain, New Delhi vs. DCIT Central Circle 32, New Delhi

Appeal is allowed

ITA 1209/DEL/2023[2012-13]Status: DisposedITAT Delhi04 Nov 2025AY 2012-13

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)

Section 147Section 148

Assessing Officer’s mind as to in whose hands a particular item of income has to be assessed; he could indeed frame a “protective” assessment so as to safeguard the interest of the revenue. A perusal of the assessee’s instant appeal file suggests that no such “substantive” addition ... either been discussed or made forming basis of the impugned protective assessment forming subject matter of challenge before us. Coupled with this case law DHFL Venture Capital Fund Vs. ITO (2013) 34 taxmann.com 300 (Bom.) has further settled the issue that the learned departmental authorities could not initiate section 148/147

Pareshbhai M Ahendrabhai, Pm Jewelwx P Ltd, Medabad vs. ACIT .Cen . Cir-2, Rajkot

In the result, the appeal of the assessee is allowed

ITA 435/RJT/2024[2018-2019]Status: DisposedITAT Rajkot03 Nov 2025AY 2018-2019

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.435/Rjt/2024 निर्धारणवर्ष /Assessment Year: 2018-19 P.M. Jewelex Pvt. Ltd. (Formerly Known As Pareshbhai 101, Shreeji Balaji Paragon, Nr. Rock Vs. Rewgency Hotel, Opp. Samartheshwar Mahadev, C. G. Road, Ahmedabad, Gujarat - 380009 Pan : Aajcp1915H (अपीलार्थी/Appellant) निर्धारिती की ओर से/Assessee By : Shri S. N. Divatia, Ar राजस्व की ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr.Dr सुनवाई की तारीख /Date Of Hearing : 05/08/2025 घोषणा की तारीख/Date Of Pronouncement : 03/11/2025 Order Per Dinesh Mohan Sinha: Captioned Appeal Filed By Assessee Pertaining To Assessment Year 2018-19, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By The Ld. Commissioner Of Income-Tax (Appeal)-11, Ahmedabad (In Short ‘Cit(A)'), Dated 10.05.2024, Which In Turn Arises Out Of Assessment Order Passed By Assessing Officer U/S. 143(3) R.W.S. 153C Of The Act On 19.12.2019.

For Appellant: Shri S. N. Divatia, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr.DR

Section 143(3)Section 153CSection 250Section 69A

unaccounted investment u/s 69A made by AO. 3.2 The Id. CIT(A) ought not to have confirmed the protective assessment in the case of appellant without ascertaining the fate in the hands of the senders of the good. 3.3 That the in the facts and circumstances

Baby Kunwar Jhala, Neemuch vs. Deputy Commissioner of Income-Tax, Udaipur

In the result, the appeals of the assesses in ITA Nos

ITA 87/JODH/2024[2010-11]Status: DisposedITAT Jodhpur30 Oct 2025AY 2010-11

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Section 148Section 68

relevantly and rationally and without reliance on facts nor furnished to the affected party. 7. The Ld. CIT(A) has erred in confirming the Protective Assessment order without providing the details of counter party and without stating in the Appellate order whether the amount advanced by the appellant had been ... tabular form as below: Appeal No. Assessee's Paper Book Page No. Amount Disputed Mode of transfer Remarks ITA No. 338/Jodh/2024 17 600000/- Bank/cheque Protective Assessment. ITA No. 351/Jodh/2024 14 700000/- Cheque -do- ITA No. 352/Jodh/2024 16 400000/- Cheque -do- ITA No. 486/Jodh/2023 31 to 34 670000/- Cheque

Pushkar Nagda, Kanakheda vs. Dy Commissioner of Incometax, Udaipur

In the result, the appeals of the assesses in ITA Nos

ITA 352/JODH/2024[2010-11]Status: DisposedITAT Jodhpur30 Oct 2025AY 2010-11

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Section 148Section 68

relevantly and rationally and without reliance on facts nor furnished to the affected party. 7. The Ld. CIT(A) has erred in confirming the Protective Assessment order without providing the details of counter party and without stating in the Appellate order whether the amount advanced by the appellant had been ... tabular form as below: Appeal No. Assessee's Paper Amount Disputed Mode of transfer Remarks Book Page No. ITA No. 338/Jodh/2024 17 600000/- Bank/cheque Protective Assessment. ITA No. 351/Jodh/2024 14 700000/- Cheque -do- ITA No. 352/Jodh/2024 16 400000/- Cheque -do- ITA No. 486/Jodh/2023 31 to 34 670000/- Cheque