https://www.taxtmi.com/caselaws?id=798030 Demand under Section 156 requires a final assessment under Section 143(3) determining the sum payable; a draft order that merely proposes variations, preserves objections, and is not followed by a final order cannot support demand or consequential penalty proceedings. Section 292B cannot retrospectively convert such a draft order into a final assessment. Further, the Section 144C draft-assessment procedure is unavailable where the Transfer Pricing Officer makes no variation to returned income, since the assessee is not an eligible assessee under Section 144C(15)(b). The draft assessment and resulting fiscal and penalty actions were therefore invalid. en-us Wed, 12 Aug 2026 00:00:00 +0530 Tue, 01 Sep 2026 08:26:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798030 Demand under Section 156 requires a final assessment under Section 143(3) determining the sum payable; a draft order that merely proposes variations, preserves objections, and is not followed by a final order cannot support demand or consequential penalty proceedings. Section 292B cannot retrospectively convert such a draft order into a final assessment. Further, the Section 144C draft-assessment procedure is unavailable where the Transfer Pricing Officer makes no variation to returned income, since the assessee is not an eligible assessee under Section 144C(15)(b). The draft assessment and resulting fiscal and penalty actions were therefore invalid. Case-Laws Income Tax Wed, 12 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798030