“reasons recorded”

ReassessmentSection 148Section 14813,127 judgments

The decision most relied on for reasons recorded is Hindustan Lever Ltd. v. R.B. Wadkar (268 ITR 332), cited in 695 judgments on BharatTax.

Leading authorities on reasons recorded

Hindustan Lever Ltd. v. R.B. Wadkar

268 ITR 332 · 2004 · High Court

695

citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

T.S. Balaram ITO v. Volkart Bros.

82 ITR 50 · 1971 · Supreme Court

382

citing judgments

A mistake apparent from the record under Section 154 must be an obvious and patent error, not one that requires a long and elaborate process of reasoning or where two opinions are conceivable. Rectification under Section 154 is not permissible for re-examining issues already considered or requiring detailed re-computation.

CIT v. Orient Craft Ltd.

354 ITR 536 · 2013 · High Court

366

citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.

384 ITR 147 · 2016 · High Court

274

citing judgments

Reassessment proceedings are invalid if initiated based on documents already available on record without fresh tangible material, and if the sanction under section 151 is accorded mechanically, indicating non-application of mind.

M/s Sahara India (Farms) v. CIT & Anr.

300 ITR 403 · 2008 · Supreme Court

268

citing judgments

The requirement of statutory prior approval by a high-ranking authority, even if administrative, serves as an in-built protection against arbitrary exercise of power by the Assessing Officer. While such approval need not record elaborate reasoning, the approving authority has a heavy duty to ensure it is not an empty ritual, fulfilling its purpose of supervisory control.

Haryana Acrylic Manufacturing Company v. CIT

308 ITR 38 · 2009 · High Court

248

citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

Pepsi Foods (P.) Ltd. v. Asstt. CIT

367 ITR 112 · 2014 · High Court

225

citing judgments

For assessments under Section 153C, a specific satisfaction note by the Assessing Officer of the person searched, recorded prior to initiating proceedings, is a jurisdictional prerequisite, rendering its absence void. The approval function under Section 153D is administrative and does not require elaborate reasoning.

Sarthak Securities Co. Pvt. Ltd. v. ITO

329 ITR 110 · 2010 · High Court

217

citing judgments

Reassessment proceedings under Section 147 are invalid if the Assessing Officer records satisfaction based on borrowed satisfaction or information without independently applying their mind and forming their own 'reason to believe' that income has escaped assessment. The AO must arrive at an independent conclusion, not merely act on a report from an investigation wing without due diligence.

Judgments citing reasons recorded

Surendra Garg HUF, Mumbai vs. ITO- 19(3)(4), Mumbai

ITA 583/MUM/2024[2013-14]Status: DisposedITAT Mumbai02 Jan 2026AY 2013-14

For Appellant: Shri Dharan GandhiFor Respondent: Shri Bhangepatil Pushkaraj Ramesh

Section 10(38)Section 143(1)Section 143(3)Section 147Section 148Section 153CSection 68

whereas the Assessing Officer ought to have initiated proceedings under Section 153C of the Act. It is the contention of the Assessee that the reasons recorded for reopening the assessment provided that the reassessment proceedings have been initiated on the basis of information/material discovered during the search proceedings conducted ... framed assessment vide Assessment Order, dated 29/12/2017, passed under Section 143(3) read with Section 147 of the Act. The reasons recorded for reopening assessment provide that reassessment proceedings were on the basis of information received from Deputy Commissioner of Income Tax (Investigation Wing), Ahmadabad. It is not the case

Deputy Commissioner of Income Tax (Central Circle)-1(4), Ahmedabad vs. Hindva Builders, Ahmedabad

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1563/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR

Section 147Section 148Section 148ASection 149Section 250Section 3(1)

settled principles of law as propounded by the Apex Court as well as by this court and considering the contention of the reasons recorded for reopening and further clarification of the information made by the revenue, we are of the view that, if the Assessing Officer himself was satisfied with

Deputy Commissioner of Income Tax, Central Circle-1(4), Ahmedabad vs. Hindva Builders, Ahmedabad

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1562/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR

Section 147Section 148Section 148ASection 149Section 250Section 3(1)

DCIT, Central Circle-1(4), Ahmedabad vs. Hindva Builders, Ahmedabad

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1451/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR

Section 147Section 148Section 148ASection 149Section 250Section 3(1)

DCIT, Central Circle-1(4), Ahmedabad vs. Hindva Builders, Ahmedabad

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1450/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2015-16

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR

Section 147Section 148Section 148ASection 149Section 250Section 3(1)

Maithan Ceramic Ltd., Kolkata vs. ACIT, Circle 7(1), Kolkata

ITA 1944/KOL/2025[2011-2012]Status: DisposedITAT Kolkata01 Jan 2026AY 2011-2012

For Appellant: Shri P.K.Himmatsinghka, ARFor Respondent: Shri Sandeep Lakra, Sr. DR

Section 142(1)Section 269S

Assessing Officer. The Id. AR subsequently drew our attention to page Nos.81 to 89 of the paper book which are the copies of the reasons recorded for the reopening of the assessment. The reads as under :- 81 Reason to Believe A.Y: 2011-12 M/s. Maithan Ceramics Limited 1. The assessee ... Agro Pvt. Ltd. had repaid on 23.01.2012 and TDS had also been deducted. It was submitted by the Id.AR that at the outset, the reasons recorded clearly showed that the Assessing Officer was doing fishing and roving enquiry which is not permissible for the purpose of reopening. It was also

Chintan Harshad Kanakia, Mumbai vs. ITO Ward 42(1)(1), Mumbai

In the result, ground No.3 of appeal is allowed

ITA 2822/MUM/2025[2015-16]Status: DisposedITAT Mumbai01 Jan 2026AY 2015-16

Bench: Shri Pawan Singhsmt Renu Jauhriassessment Year: 2015-16 (Hybrid Hearing) Chintan Harshad Kanakia, Ito Ward 42 (1)(1) Room No. 103, Sacovar Apt., Sagar Complex, 703, Kautilya Bhavan, Vs. Saibaba Nagar, Borivali (W), Bkc, Mumbai -400051 Mumbai Pan – Agnpk6023E

Section 10(38)Section 132Section 143(2)Section 148Section 148ASection 151ASection 234BSection 254(1)Section 271(1)(c)

directed to be considered as deemed notice under Section 148A. As per direction of the Hon’ble Apex Court the assessee was provided reasons recorded, information and material relied by the Revenue. The information and material was provided to the assessee on 31.05.2022 with the direction to furnish reply within ... void ab initio and entire assessment is bad in law. The assessee also raised plea that no addition was made on the reasons recorded and that additions were mode on different issue, which is not permissible. The assessee also challenged the validity of addition in disallowing exemption for not qualifying

Ajaykumar Natwarlal Sheth, Rajkot vs. The DCIT, Circle 1(2) Rajkot, Rajkot

ITA 108/RJT/2025[2010-11]Status: DisposedITAT Rajkot31 Dec 2025AY 2010-11

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

Transactions alleged of client code modification with all Break-up (order & trade Log/Number) as there is no clarity in the figures shown in reasons recorded as well as in the show cause notice issued by you wherein the figures are not much with each other. Thus, it requires detailed information ... Parliament is stronger than the expression 'satisfied' and in the present case such requirement as contemplated by law has not been met in the 'reason recorded' by the assessing officer before venturing to re-open the assessment which vitiates the re-opening itself. I note that even if the information

Kanhaiya Lal Hari Narayan, Neem Ka Thana vs. Income Tax Officer, Ward Neem Ka Thana, Neem Ka Thana

The appeal of the assessee is allowed in above terms

ITA 1034/JPR/2025[2013-14]Status: DisposedITAT Jaipur31 Dec 2025AY 2013-14

Bench: SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: Sh. Vedant Gupta, AdvocateFor Respondent: Sh. Gautam Singh Choudhary

Section 144Section 147Section 250

validity of jurisdiction assumed by the AO to frame assessment u/s. 147 of the Act, He contended that it was stated that while the reasons recorded mentioned escapement of income for Financial Year 2011-12 relevant to Assessment Year 2012-13, the jurisdiction to reopen the case of the assessee ... submission of ground No. 1, 4 & 5 of written submission of the appellant on contrary to the assessment order, appellant has objected that reason recorded by the DDIT(Investigation wing), Karnal for the A.Y. 2012-13 are related for escaped income of Rs. 6,96,000/-, however, reassessment proceedings

Vikas Jain, Kanpur vs. ACIT-CC 2(1)(1), Kanpur

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

ITA 434/LKW/2024[2015-16]Status: DisposedITAT Lucknow31 Dec 2025AY 2015-16

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2015-16 Vikas Jain, Vs. The Acit, H-2/1, Kidwai Nagar, Kanpur- Circle 2(1)(1), Kanpur 208001 208006 Pan: Abqpj8049R (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 07.10.2025 Date Of Pronouncement: 31.12.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac On 17.05.2024 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Order Passed By The Ld. Assessing Officer Under Section 147 R.W.S. 143(3) For The A.Y. 2015-16 On 27.12.2018. The Grounds Of Appeal Are As Under:- “01. Because There Being No Reason To Believe, Far From There Being Any Material To Form Reasons To Believe, The Proceedings Initiated Right From Issue Of Notice U/S. 148 & The Re-Assessment Framed Thereof Are All Without Jurisdiction Bad In Law, The Order Passed Be Quashed. 02. Because The So-Called Reasons Having Been Recorded Applying Explanation 2(A) To Section 147, Of The Act Which Not Being Applicable, The Very Reason To Believe Being Contrary To The Mandate Of The Section, The Proceedings- Initiated U/S 148, The Reassessment Framed Are All Contrary To The Provisions Of Law, Be Quashed. 03. Because The Approval Given By The Competent Authority U/S 151, Being Mechanical In Nature Without Verification Of Facts, The Notice Issued U/S 148 & The Reassessment Framed Thereafter Be Quashed.

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. Amit Kumar, DR

Section 143(1)Section 147Section 148Section 151Section 156Section 48Section 50C

assessment records. Since, the notice under section 148 had been issued on the premise that he had not filed his return of income, the reasons recorded were factually incorrect and the issue of the notice was mechanical due to which the notice itself ... care certain situations and enables the income tax authorities to cure defects in orders, notices etc., but the jurisdiction to reopen emerges from the reasons recorded in writing under section 148(2) on the strength of, ‘reason to believe’ towards escapement of income. It is those reasons that confer assumption

Dharam Chand Agarwal, Kanpur (Uttar Pardesh) vs. Principal Commissioner of Income Tax, Kanpur- I

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

ITA 358/LKW/2024[2016-2017]Status: DisposedITAT Lucknow31 Dec 2025AY 2016-2017

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2016-17 Dharam Chand Agarwal, Vs. Pr. Commissioner Of Income Tax, 14/75 D Gopal Vihar Civil Lines, Kanpur-I, U.P. Kanpur, U.P. Pan: Aanpa1942L (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. R.K. Agarwal, Cit Dr Date Of Hearing: 07.10.2025 Date Of Pronouncement: 31.12.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Pr. Cit, Kanpur-1 On 31.03.2024 Under Section 263 Of The Income Tax Act, 1961, Wherein The Ld. Pcit Has Set Aside The Order Passed By The Ld. Ao On 28.03.2022 Under Section 147 R.W.S. 144B For The A.Y. 2016-17 & Directing Him To Pass A Fresh Assessment Order. The Grounds Of Appeal Are As Under:- “1. Because The Assessment Order U/S 147 R.W.S 144 Dated 28.03.2022, Which Has Been Set Aside U/S 263 Of The Act By The Impugned Order Passed By Pr. Cit, Itself Was Illegal & Was Not Enforceable Due To Various Infirmities In The Initiation & Conclusion Of Re-Assessment Proceedings, The Same Could Not Have Been Subjected To Revision U/S 263 Of The Act & Consequently The Impugned Order Is Bad In Law & Wholly Without Jurisdiction. Without Prejudice To The Aforesaid 2. Because The Pr. Cit Has Erred In Law & On Facts In Holding That The Assessment Order Dated 28.03.2022 Passed By The Assessing Officer, Nfac U/S 147 R.W.S 144B Of The Act Is Erroneous In So Far As It Is Prejudicial To The Interest Of Revenue & In Setting Aside The Same By Exercising His Revisionary Jurisdiction U/S 263 Of The Act.

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. R.K. Agarwal, CIT DR

Section 133ASection 147Section 148Section 263

Tribunal had held that the PCIT could not revise an order where the 4 Dharam Chand Agarwal A.Y. 2016-17 very basis of the reasons recorded by the AO to reopen the case was not added back in the re-assessment proceedings, because the primary reason to believe that ... validity of the assessment order but whether any addition could be made on, “other item of income” which did not form the basis of reasons recorded and sanction obtained for, if the item of income on which the reasons were recorded and sanction was obtained was not assessed

Shree Krishna Gyanodaya Flour Mills Pvt. Ltd., Kolkata vs. ACIT, Central Circle 4(3), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2179/KOL/2025[2011-2012]Status: DisposedITAT Kolkata31 Dec 2025AY 2011-2012

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Shree Krishna Gyanodaya Acit, Central Circle 4(3) Flour Mills Pvt. Ltd. Aaykar Bhawan Poorva 15Th Floor, 46C, Chowringhee 110, Kolkata-700107, Vs. Road, Everest House, Kolkata- West Bengal 700071, West Bengal (Appellant) (Respondent) Pan No. Aahcs8774P Assessee By : Shri S.K. Tulsiyan, Ar Revenue By : Shri Sanat Kumar Raha, Dr Date Of Hearing: 01.12.2025 Date Of Pronouncement: 31.12.2025

For Appellant: Shri S.K. Tulsiyan, ARFor Respondent: Shri Sanat Kumar Raha, DR

Section 139(1)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 151(1)Section 153ASection 68

assessment proceedings. However, we note that Shree Krishna Gyanodaya Flour Mills Pvt. Ltd. the ld. AO has not recorded any such satisfaction in the reasons recorded for reopening of assessment. We note that the assessee has raised specific objection on this before the ld. AO and the ld. AO while ... materials on record, we are of the view that the AO while disposing off the preliminary objections filed by the writ applicant against the reasons recorded for reassessment, has not properly dealt with the objections. In the base of GKN Driveshafts India Ltd. (supra). the Supreme Court has laid down

The Great Getsby Club of India, Delhi vs. ITO Ward 2(3), Delhi

In the result, appeal of the assessee is allowed

ITA 7144/DEL/2025[2014-15]Status: DisposedITAT Delhi31 Dec 2025AY 2014-15

Bench: the First Appellate Authority. The CIT(A) sought remand report from the AO but no finding was given by the CIT(A) on the issue. The fact that the notice u/s.148 of the Act dated 19.01.2016 was issued prior to seeking approval from the Competent Authority and recording of reasons is unrebutted. Thus, it is evident that on the date of issuance of notice u/s.148 of the Act, the AO had no subjective satisfaction or reasons to reopen assessment. The assessment cannot be reopened without there be

For Appellant: Dr. Kapil Goel, Advocate (Through VC)For Respondent: Shri Manoj Kumar, Sr. DR

Section 148

assailed validity of the notice issued u/s.148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) on the ground that the reasons recorded for issuing notice u/s.148 of the Act and approval from the Competent Authority is after issuance of notice u/s.148

Dy. Commissioner of Income Tax, Central Circle-3, Delhi vs. Apoorva Leasing Finance and Investment Company Ltd., Delhi

In the result, the appeal is partly allowed

ITA 635/DEL/2025[2011-12]Status: DisposedITAT Delhi31 Dec 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarassessment Year : 2011-12 Dcit, Vs. Apoorva Leasing Finance & Central Circle-3, Investment Company Ltd., Delhi. Third Floor, 13/331, Geeta Colony, Delhi – 110 031. Pan: Aabca0282A Co No.179/Del/2025 (Ita No.635/Del/2025) Assessment Year : 2011-12 Apoorva Leasing Finance & Vs. Dcit, Investment Company Ltd., Circle-3(1), Third Floor, 13/331, New Delhi. Geeta Colony, Delhi – 110 031. Pan: Aabca0282A (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate & Shri Somil Agarwal, Advocate Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 30.10.2025 Date Of Pronouncement : 31.12.2025 Order Per Vimal Kumar, Jm:

For Appellant: Dr. Rakesh Gupta, Advocate &For Respondent: Shri Om Parkash, Sr. DR

Section 143(1)Section 143(3)Section 147Section 148Section 153CSection 250

investments. Total amount of such accommodation entries thus, comes to Rs. 57,48,50,000/- and the commission income @1.75% as per the reasons recorded, comes to Rs. 1,00,59,875/-. Hence, an addition of Rs. 1,00,59,875/- is hereby made on account of commission income which ... addition of Rs. 1,00,59,875/- be deleted.’ 16.2 The submissions of the appellant have been considered. As is clear from the reasons recorded and other contents of the assessment order, the complete case against the assessee is based on Investigation Report which has transactions upto June

Manohar Filaments Pvt Ltd, Delhi vs. PCIT, (Central)-3, Delhi

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

ITA 2644/DEL/2025[2016-17]Status: DisposedITAT Delhi31 Dec 2025AY 2016-17

Bench: Shri C.N. Prasad & Shri M. Balaganesh[Assessment Year: 2016-17 ] Manohar & Filaments Pvt. `Vs. Pcit, (Central)-3, Delhi Ltd, B-59, G. T. Karnal Road, Industrial, Area, New Delhi Pan No.Aaacm1116E Appellant Respondent

Section 153CSection 153DSection 263

proceedings and also the validity of reopening u/s.147 when it was not challenged by the assessee; and secondly, whether the reopening based on the reasons recorded by the Assessing Officer itself was bad in law or not. 18. This precise issue has been dealt in detail by the Coordinate Bench ... erroneous and prejudicial to the interest of the Revenue. In the present case, the Assessing Officer did not make any addition for the reasons recorded at the time of issue of notice under Section 148 of the Act. This position is not disputed and disturbed by the Commissioner of Income

New Track Exim Private Limited, Delhi vs. Income Tax Officer, Ward 18(3), Delhi

In the result, appeal of the assessee is partly allowed

ITA 2765/DEL/2024[2012-13]Status: DisposedITAT Delhi31 Dec 2025AY 2012-13

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 151Section 250Section 68

same income as was declared in the return filed u/s 139(1) of the Act. Assessee then, requested for the supply of the reasons recorded before initiating reh proceedings u/s 147 of the Act which were supplied and assessee filed objections against reopening the assessment. The same were disposed ... given without applying the mind, solely based on the information supplied by the Investigation Wing, Kolkata. The Ld. AR drew our attention to the reasons recorded wherein the Assessing Officer has observed that enquiries were carried by the Investigation Wing, Kolktta and further observed that the company M/s Oven Commercial

Sunita Bhardwaj, New Delhi vs. ITO Ward 61(1), New Delhi

In the result appeal of the assessee is partly allowed

ITA 1431/DEL/2024[2016-2017]Status: DisposedITAT Delhi31 Dec 2025AY 2016-2017

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL (Accountant Member)

Section 147Section 151Section 234ASection 250Section 69A

PCIT. 4. Heard both the parties and perused the materials available on record. The case of the assessee is reopened in terms of the reasons recorded and approval granted u/s 151 of the Act on 30.03.2021. The necessary copy of the approval is placed in the paper book filed

Sunita Bhardwaj, New Delhi vs. ITO Ward 61(1), New Delhi

In the result appeal of the assessee is partly allowed

ITA 1430/DEL/2024[2017-2018]Status: DisposedITAT Delhi31 Dec 2025AY 2017-2018

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL (Accountant Member)

Section 147Section 151Section 234ASection 250Section 69A

Sunita Bhardwaj, New Delhi vs. ITO Ward 61(1), New Delhi

In the result appeal of the assessee is partly allowed

ITA 1429/DEL/2024[2018-2019]Status: DisposedITAT Delhi31 Dec 2025AY 2018-2019

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL (Accountant Member)

Section 147Section 151Section 234ASection 250Section 69A

Bechtel Ltd, London vs. ACIT, Circle 1(1)(2), International Taxation, New Delhi

In the result, appeal of the assessee is allowed

ITA 756/DEL/2023[2020-21]Status: DisposedITAT Delhi31 Dec 2025AY 2020-21

Section 143(2)Section 143(3)Section 144C(13)Section 44DSection 9(1)(vii)

draft assessment order under Section 144C (1) of the Act and the said final assessment order has been held by this Court, for the reasons recorded hereinabove, to be invalid. 44. The other plea of the Revenue that the Petitioners ought to have challenged the final assessment order before