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TMI Blog2023 (8) TMI 1260X X X X Extracts X X X X X X X X Extracts X X X X ..... d 27.05.2021, the first respondent has added several amounts to the income disclosed by the petitioner in the Returns filed under Section 139 of the Income Tax Act, 1961. 3. It is the specific case of the petitioner that as far as the petitioner is concerned, the petitioner is also an eligible assessee under the provisions of Section 144C of the Income Tax Act, 1961 and a portion of the assessment was before the Transfer Pricing Officer. As far as non transfer pricing issues which are regular corporate issues are concerned, the respondents were required to comply with the requirements of Section 144B(1) (xvi)(b). However, without complying with the same, the Impugned Order has been passed under Section 144C of the Income Tax Act, 1961. 4. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unit was required to make a Draft Assessment Order after taking into account all relevant materials available on the records or in a case where intimation referred to in clause (xii) was received from the National Faceless Assessment Centre make a Draft Assessment Order to the best of its judgment, either accepting the income or was payable or was refundable to the assessee as per his Return or making such variation to the said income or same and send a copy of the said order to the National Faceless Assessment Centre. 10. Sub clause (xiv) to Sub clause (1) to Section 144B of the Income Tax Act, 1961 reads as under: "(xiv) the assessment unit shall, after taking into account all the relevant material available on the record make in writi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h an automated allocation system, for conducting review of such order. 12. What follows the above is enumerated in Sub clause (xvii) & Sub clause (xviii) to Sub clause (1) to Section 144B of the Income Tax Act, 1961, which reads as under: 144B(1)(xvii) 144B(1)(xviii) The review unit shall conduct review of the draft assessment order referred to it by the National Faceless Assessment Centre whereupon it may decide to:- (a) concur with the draft assessment order and intimate the National Faceless Assessment Centre about such concurrence; or (b) suggest such variation, as it may deem fit, in the draft assessment order and send its suggestions to the National Faceless Assessment Centre. The National Faceless Assessment Centre shall, upo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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