https://www.taxtmi.com/caselaws?id=783807 Where the assessee is an "eligible assessee" under s. 144C(15)(b) and the AO proposes variations prejudicial to it, issuance of a draft assessment order under s. 144C(1) and recourse to the DRP mechanism is mandatory and overriding, including in assessments framed under s. 153A, by virtue of the non obstante scheme of s. 144C. Non-issuance of a draft order is a fatal, incurable jurisdictional defect not curable under s. 292B, and participation cannot validate a void order; further, the statutory time-limits under s. 144C bar any belated final order. Accordingly, the final assessment orders passed without a draft order were held void ab initio and were quashed, and the appeals were allowed. en-us Mon, 15 Dec 2025 00:00:00 +0530 Tue, 23 Dec 2025 07:59:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783807 Where the assessee is an "eligible assessee" under s. 144C(15)(b) and the AO proposes variations prejudicial to it, issuance of a draft assessment order under s. 144C(1) and recourse to the DRP mechanism is mandatory and overriding, including in assessments framed under s. 153A, by virtue of the non obstante scheme of s. 144C. Non-issuance of a draft order is a fatal, incurable jurisdictional defect not curable under s. 292B, and participation cannot validate a void order; further, the statutory time-limits under s. 144C bar any belated final order. Accordingly, the final assessment orders passed without a draft order were held void ab initio and were quashed, and the appeals were allowed. Case-Laws Income Tax Mon, 15 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783807