https://www.taxtmi.com/caselaws?id=797239 A draft assessment order under Section 144C cannot support a tax demand or penalty proceedings because it only proposes variations and does not determine the sum payable as required for a final assessment. Section 292B cannot cure an order expressly issued as a draft or retrospectively convert it into a final assessment. Where the Transfer Pricing Officer proposes no variation to international transactions because an advance pricing agreement covers the relevant year, the taxpayer is not an eligible assessee for the draft-assessment procedure. A draft order issued in those circumstances, and consequential demand and penalty actions, lack legal foundation and are annulled. en-us Fri, 14 Aug 2026 00:00:00 +0530 Wed, 19 Aug 2026 08:20:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797239 A draft assessment order under Section 144C cannot support a tax demand or penalty proceedings because it only proposes variations and does not determine the sum payable as required for a final assessment. Section 292B cannot cure an order expressly issued as a draft or retrospectively convert it into a final assessment. Where the Transfer Pricing Officer proposes no variation to international transactions because an advance pricing agreement covers the relevant year, the taxpayer is not an eligible assessee for the draft-assessment procedure. A draft order issued in those circumstances, and consequential demand and penalty actions, lack legal foundation and are annulled. Case-Laws Income Tax Fri, 14 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797239