https://www.taxtmi.com/caselaws?id=794918 Section 144C(1) requires the Assessing Officer to first issue a draft assessment order where a proposed variation, including a transfer pricing adjustment, is prejudicial to an eligible assessee. This preserves the assessee's statutory right to raise objections before the Dispute Resolution Panel. Passing a final assessment order directly after receiving the Transfer Pricing Officer's adjustment bypasses that mandatory mechanism. The omission is a foundational jurisdictional defect, not a curable procedural irregularity under Section 292B, and invalidates the assessment proceedings. The assessment order was therefore annulled. en-us Thu, 09 Jul 2026 00:00:00 +0530 Tue, 14 Jul 2026 08:26:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794918 Section 144C(1) requires the Assessing Officer to first issue a draft assessment order where a proposed variation, including a transfer pricing adjustment, is prejudicial to an eligible assessee. This preserves the assessee's statutory right to raise objections before the Dispute Resolution Panel. Passing a final assessment order directly after receiving the Transfer Pricing Officer's adjustment bypasses that mandatory mechanism. The omission is a foundational jurisdictional defect, not a curable procedural irregularity under Section 292B, and invalidates the assessment proceedings. The assessment order was therefore annulled. Case-Laws Income Tax Thu, 09 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794918