2017 (7) TMI 1077

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..... of the Act, it is incumbent upon the AO to pass a draft assessment order under Section 144C of the Act, is the settled legal position as explained by the Court in its decision in Turner International India Pvt. Ltd. Vs. DCIT, (2017 (5) TMI 991 - DELHI HIGH COURT). In the present case, clearly the AO overlooked the above legal position and proceeded to pass a final assessment order, thereby deprivi .....

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..... oviding specialist risk consultancy services. Consequent upon the return filed by the Assessee for the AY in question, a draft assessment order was passed by the AO on 16th March, 2015 making inter alia the following conditions/disallowance:- (i) Transfer pricing adjustment: Rs.2,29,27,042/- (ii) Disallowance of interest on late deposit of TDS Rs.5,35,894/- 3. Aggrieved by the abovementioned .....

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..... ng order. 5. The TPO then undertook a fresh benchmarking analysis and passed an order dated 31st March, 2017 proposing an adjustment of ₹ 1,19,49,680/- to the Arm's Length Price ('ALP') determined by the Petitioner. 6. Thereafter, instead of passing a draft assessment order, the AO passed a final assessment order on 11th May, 2017 which has been challenged by the Petitioner in this writ pe .....

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