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The Tribunal held that the AO's assessment order was void for not following the mandatory procedure under Section 144C, which requires a draft assessment order before a final order when there's a prejudicial variation. Consequently, the Principal CIT's revisionary order under Section 263 was also deemed a nullity as it was based on a void assessment order.
The Tribunal held that the AO's assessment order was void for not following the mandatory procedure under Section 144C, which requires a draft assessment order before a final order when there's a prejudicial variation. Consequently, the Principal CIT's revisionary order under Section 263 was also deemed a nullity as it was based on a void assessment order.