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2020 (1) TMI 687 - AT - Income TaxRevision u/s 263 - order was passed u/s 143(3) r.w.s 144C - the same was subject to review by the Dispute Resolutions Panel (DRP) - Additional grounds raised - HELD THAT:- Additional grounds raised by the Ld. AR are legal ground, in light of decision of National Thermal Power Company Ltd. [1996 (12) TMI 7 - SUPREME COURT] we admit these ground Order under Section 263 was passed against the draft assessment order. The said draft assessment order was adjudicated before the DRP, therefore, it was in the matter of scrutiny before the Resolution Panel. The draft assessment order is not a final order or is not any order which is described u/s 263. It is a proposal given to the assessee upon which the assessee has a right to raise objections before the Dispute Resolution Panel. This mechanism is developed in respect of certain specialized matters. The Dispute Resolution Panel has a full authority to direct/propose certain additions or to delete certain additions. Therefore, it is a foolproof mechanism which cannot be doubted by Pr. CIT by invoking Section 263 which is a revisional power in respect of final assessment order or any order but not to a proposal which is called draft assessment order. Thus, we are allowing additional grounds which are preliminary grounds raised in respect
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