https://www.taxtmi.com/caselaws?id=799308 Section 170A(2)(b) requires a modified return filed during pending assessment proceedings following a business reorganisation to be considered within those existing proceedings. A draft assessment order does not end the assessment because the DRP process continues until a final appealable order is passed. Section 170A(3) does not create a separate assessment cycle or allow general assessment provisions to override this specific mechanism. Where the modified return has been considered in the pending assessment and a final order issued, a fresh scrutiny notice, consequential transfer-pricing reference, and parallel proceedings lack statutory basis and suffer from a jurisdictional defect. en-us Tue, 08 Sep 2026 00:00:00 +0530 Sat, 19 Sep 2026 08:20:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799308 Section 170A(2)(b) requires a modified return filed during pending assessment proceedings following a business reorganisation to be considered within those existing proceedings. A draft assessment order does not end the assessment because the DRP process continues until a final appealable order is passed. Section 170A(3) does not create a separate assessment cycle or allow general assessment provisions to override this specific mechanism. Where the modified return has been considered in the pending assessment and a final order issued, a fresh scrutiny notice, consequential transfer-pricing reference, and parallel proceedings lack statutory basis and suffer from a jurisdictional defect. Case-Laws Income Tax Tue, 08 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799308