https://www.taxtmi.com/caselaws?id=785449 Revision under section 263 was invoked for non-compliance with the draft assessment procedure under section 144C, with the revisional authority setting aside a crystallised final assessment and directing the assessing officer to pass a fresh assessment de novo; consequence: the AO must revert to the stage of the transfer pricing officer's upward adjustment recommendation and rework the assessment while considering earlier and newly discussed issues. The AO was held not entitled to bypass the draft assessment framework and directly pass a fresh order ignoring the Section 144C process. en-us Tue, 06 Jan 2026 00:00:00 +0530 Fri, 23 Jan 2026 09:10:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785449 Revision under section 263 was invoked for non-compliance with the draft assessment procedure under section 144C, with the revisional authority setting aside a crystallised final assessment and directing the assessing officer to pass a fresh assessment de novo; consequence: the AO must revert to the stage of the transfer pricing officer's upward adjustment recommendation and rework the assessment while considering earlier and newly discussed issues. The AO was held not entitled to bypass the draft assessment framework and directly pass a fresh order ignoring the Section 144C process. Case-Laws Income Tax Tue, 06 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785449