https://www.taxtmi.com/caselaws?id=752169 Under the unamended Section 144C of the Income-tax Act, the draft assessment order procedure applied only where there was a variation in the returned income or loss of an eligible assessee. A change only in the tax consequence, such as denial of treaty benefit and application of a higher tax rate, did not satisfy that pre-amendment condition when the returned income itself remained unchanged. The later amendment extending the provision to any variation prejudicial to the assessee was not applicable to the assessment years in question, so the draft assessment mechanism was not attracted on those facts. en-us Fri, 16 Feb 2024 00:00:00 +0530 Sat, 04 May 2024 08:00:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752169 Under the unamended Section 144C of the Income-tax Act, the draft assessment order procedure applied only where there was a variation in the returned income or loss of an eligible assessee. A change only in the tax consequence, such as denial of treaty benefit and application of a higher tax rate, did not satisfy that pre-amendment condition when the returned income itself remained unchanged. The later amendment extending the provision to any variation prejudicial to the assessee was not applicable to the assessment years in question, so the draft assessment mechanism was not attracted on those facts. Case-Laws Income Tax Fri, 16 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752169