https://www.taxtmi.com/caselaws?id=471363 Draft-assessment and Dispute Resolution Panel procedure applies only to an eligible assessee, including one facing a prejudicial variation arising from a Transfer Pricing Officer's order. An assessee that is neither a foreign company nor subject to any transfer-pricing variation cannot be treated as eligible merely because transfer-pricing proceedings occurred. Applying the procedure without a qualifying variation exceeds jurisdiction; the draft assessment order and resulting Dispute Resolution Panel directions are liable to be quashed. en-us Tue, 16 Dec 2025 00:00:00 +0530 Mon, 31 Aug 2026 18:58:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471363 Draft-assessment and Dispute Resolution Panel procedure applies only to an eligible assessee, including one facing a prejudicial variation arising from a Transfer Pricing Officer's order. An assessee that is neither a foreign company nor subject to any transfer-pricing variation cannot be treated as eligible merely because transfer-pricing proceedings occurred. Applying the procedure without a qualifying variation exceeds jurisdiction; the draft assessment order and resulting Dispute Resolution Panel directions are liable to be quashed. Case-Laws Income Tax Tue, 16 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471363