Issuance of draft assessment order along with demand notice is bad in law

Marriott International Licensing Company BVV Vs DCIT (ITAT Mumbai) ITAT Mumbai held that issuance of draft assessment order along with the demand notice is in violation of provisions of section 144C of the Income Tax Act and hence bad in law. Facts- The assessee has challenged the order of the ld. CIT(A) in holding that the receipts raised pursuant to the International Marketing Program Participation Agreement (IMPPA for short) are taxable in India and taxing IMPAA receipts in India as ‘business income’ on the basis that the assessee has permanent establishment in India as per the provisio...