The AO held that the Assessee is not a beneficial owner of the interest income and thereby issued a draft assessment order and final assessment order on 28.12.2018 and 22.02.2019  taxing the said income at 30%. Tribunal held that  there was no proposal for variation in the returned income of the Assessee in the instant case. Further, while referring to other orders of the co-ordinate bench on the same issue, held that for the AYs before the amendment in section 144C which came into effect from 01.04.2020, the cases in which no variation in the return of income or loss were proposed, the draft assessment orders were not required to be issued. Accordingly, no extended period for concluding the assessment was available. Order is barred by limitation. (AY .2016-17)