Modified returns of income filed following business...

Modified returns of income filed following business reorganisation must be considered within the assessment proceedings already pending for the relevant assessment year. A draft assessment order does not conclude those proceedings, as the Dispute Resolution Panel process remains part of the assessment machinery until a final appealable order is issued. Section 170A does not extinguish the existing assessment or permit a separate, parallel scrutiny process for the modified return. A scrutiny notice issued without jurisdiction cannot support a transfer pricing reference; consequential Transfer Pricing Officer proceedings and notices founded on that scrutiny are unsustainable and liable to be quashed.