https://www.taxtmi.com/highlights?id=92245 The HC held that where the TPO's determination implementing the Tribunal's directions results in a variation in the Arm's Length Price (ALP), the Assessing Officer (AO) is statutorily obliged to issue a draft assessment order under s.144C(1) read with s.92CA(3). The Court rejected Revenue's contention that mere implementation of Tribunal directions without an independent finding absolves the AO from issuing a draft order, finding that the Tribunal left ALP determination to the TPO's discretion and that such variation triggers the mandatory draft-order procedure. Consequently the assessment rendered without issuance of the s.144C draft assessment order was unsustainable. en-us Fri, 05 Sep 2025 08:10:37 +0530 Fri, 05 Sep 2025 08:10:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=92245 The HC held that where the TPO's determination implementing the Tribunal's directions results in a variation in the Arm's Length Price (ALP), the Assessing Officer (AO) is statutorily obliged to issue a draft assessment order under s.144C(1) read with s.92CA(3). The Court rejected Revenue's contention that mere implementation of Tribunal directions without an independent finding absolves the AO from issuing a draft order, finding that the Tribunal left ALP determination to the TPO's discretion and that such variation triggers the mandatory draft-order procedure. Consequently the assessment rendered without issuance of the s.144C draft assessment order was unsustainable. Highlights Income Tax Fri, 05 Sep 2025 08:10:37 +0530 https://www.taxtmi.com/highlights?id=92245