Non-passing of draft assessment order u/s 144C(1) renders final assessment Jurisdictionless

CWT India Private Limited Vs ACIT (Bombay High Court) Bombay High Court held that failure to pass a draft assessment order under section 144C(1) of the Income Tax Act results in rendering the final assessment as one without jurisdiction. Facts- Petitioner filed its return of income for the respective years and the return of income was processed u/s. 143(1) of the Income-tax Act, 1961. Subsequently, the case was selected for scrutiny and statutory notices were issued in both. As there were international transactions, a reference was made by the Assessing Officer (“AO”) to the Transfer Prici...