Proceedings initiated u/s 144C - legality of the order by...

Proceedings initiated u/s 144C - legality of the order by framing the so-called draft assessment order - while framing the said draft assessment order, the AO not only issued and served demand notice, but has also initiated the penalty proceedings. - no hesitation to hold that the proceedings, when the demand notice was issued and served upon the assessee and penalty proceedings were simultaneously initiated making all subsequent proceedings and orders non-est. - AT