October 1, 2009, the
cut-off date prescribed in sub-section (1) of
section 144C , the Assessing Officer is
mandated to first pass a draft ... tenable in as much
as the language of sub-section (1) of section
144C referring to the cut-off date of
October 1, 2009, indicates
petitioner u/s
u/s 139(1) of the IT 139(1) of the IT act
act
2. 31.03.2021 Notice ... Notice u/s 142 (1) 13 .07.2021 Notice u/s 142 (1)
5 . 22.07.2021 Reply to Notice u/s 22 .07.2021 Reply to Notice
Pricing Officer passed under sub-section (3)
Officer passed under sub-section of section 92CA ; and
(3) of section 92CA ; and (ii) any non-resident ... tenable in as much as the
language of Sub-section (1) of Section 144C
referring to the cut off date of 01.10.2009
indicates an intention
said
decision is reproduced hereunder:
“6. The interpretation of sub-section (13) of section 144C takes centre
stage in the adjudication of this dispute ... date of receipt
of directions issued under sub-section (5) thereof. Sub-section (5) of
section 144C deals with the issuance of directions
submitted that the provisions of Sub Section (2) to Section
144C of the Income Tax Act, 1961, mandate that on receipt of the draft
order ... umbrage under Section
292B . Allowing such a contention would
be misreading the intention of the
Parliament in enacting Section 292B and
Section 144C
pass the impugned assessment
order dated 19.05.2025 under Section 147 read with Section 144C(3) on the
assumption that the petitioner had accepted the aforesaid ... issued under Section 148A(b) to Order dated
28.03.2024 passed under Section 144A(d) and Draft Assessment Order dated
11.03.2025 under Section 144C
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 ... Section 144C read with Section 153 of the Income Tax
Act, 1961.
27. As per Sub-Section (13) to Section 144C of the Income
objection had expired as per section 144C(4) . Sub-section
(5) of section 144C of the Act provides that if any objections
are raised ... from the
date when the assessee submits the objections. Sub-section
(13) of section 144C of the Act provides that upon receipt of
directions issued
interest of such assessee, as mentioned in sub-
section (1) under section 144C , the National Faceless
Assessment Centre shall serve the draft order referred ... Faceless Assessment Centre,
within the period specified in the sub-section (2) of Section
144C ;
xxv) the National Faceless Assessment Centre shall,-
(a) upon receipt
Assessment Year
2012-2013under Section 143(3) read with Section 144C of the Income
Tax Act,1961.
https://www.mhc.tn.gov.in/judis ... dated 28.12.2019 also has been
passed under Section 143(3) read with Section 147 read with Section
144C(1) of the Income Tax Act, 1961for
