https://www.taxtmi.com/caselaws?id=307813 Section 144C can be invoked only when the Assessing Officer proposes a variation in returned income or loss that is prejudicial to the assessee; where the returned income is accepted without variation, the draft assessment procedure is not attracted and the normal limitation under section 153 applies. On that basis, an assessment order passed beyond the permissible time could not stand. The Dispute Resolution Panel also cannot record substantive findings on beneficial ownership or treaty entitlement after holding that the objection itself was beyond the scope of section 144C, because such findings are outside its jurisdiction and cannot bind future years. en-us Fri, 17 Jan 2020 00:00:00 +0530 Tue, 09 May 2023 21:17:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307813 Section 144C can be invoked only when the Assessing Officer proposes a variation in returned income or loss that is prejudicial to the assessee; where the returned income is accepted without variation, the draft assessment procedure is not attracted and the normal limitation under section 153 applies. On that basis, an assessment order passed beyond the permissible time could not stand. The Dispute Resolution Panel also cannot record substantive findings on beneficial ownership or treaty entitlement after holding that the objection itself was beyond the scope of section 144C, because such findings are outside its jurisdiction and cannot bind future years. Case-Laws Income Tax Fri, 17 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307813