Sec. 144C of the Act in the context of
'eligible assessee' prescribed therein. Sec. 144C of the Act contains 15 sub-
sections ... Sec. 144C(15)(b)(i) of the Act. Notably, sub-clause (i) of
clause (b) of sub- section 15 of Sec. 144C
section 144C(1) of the Act. He
submitted, the Assessing Officer can pass a draft assessment order
under sub-section (1) of section 144C ... prejudicial to the interest of the said assessee. Sub-section
(15)(b) of section 144C of the Act defines eligible assessee as under:-
"(15
assessee‖. The expression ―eligible assessee‖
has been defined in sub-section (15) to section 144C of the Act . The definition
of eligible assessee is reproduced ... assessee' for the purpose of section 144C. The relevant provisions of section
144C(1) and sub section 15 reads as under:-
144C
provisions of section 144C would not be applicable, as the
Assessee is not an 'eligible assessee' u/s 144C(15). Reliance has
been ... passed
under sub-section (3) of section 92CA; and
(ii) any foreign company."
23. Thus, as per section 144(15)(b) , 'eligible assessee
section (3) of
section 92CA ; and
(ii) any foreign company.”
7. Plain reading of clause-(b) of Sub-
section(15) of Section 144C would show ... virtue of Section 144C read with Section 153 of the Income Tax
Act, 1961.
27. As per Sub-Section (13) to Section 144C
under Section 144C and the Final
Assessment Order dated 7th April 2025 passed under
Section 143 (3) read with Section 144C and Section 144B ... section (3) of section 92CA; and
(ii) any foreign company."
7. Plain reading of clause (b) of sub-section
(15) of section 144C would
eligible assessee" as
defined in clause (b) of sub- section 15 of Section 144C of the I. T. Act. Once
this is the case ... section
(3) of section 92CA; and
(ii) any foreign company."
7. Plain reading of clause (b) of sub-section (15) of
section 144C would
eligible assessee‟ for the
purpose of section 144C . The relevant provisions of section 144C(1)
and sub section 15 reads as under:-
144C ... thus, a resident in India under section 6 of the Act. Thus, the second
condition under section 144C (15
insertion of Sec. 144C of the Act in
the context of „eligible assessee‟ prescribed therein. Sec. 144C of
the Act contains 15 subsections and provides ... eligible
assessee‟ for the purpose of section 144C. The relevant provisions
of section 144C(1) and sub section 15 reads as under
insertion of Sec. 144C of the Act in the context of „eligible
assessee‟ prescribed therein. Sec. 144C of the Act contains 15
subsections and provides ... assessee' for the purpose of section 144C. The
relevant provisions of section 144C(1) and sub section 15 reads
as under:-
144C