Dismissing the appeal of the Revenue the Court held that since at the stage of passing draft order, ACIT had assessed tax,passed final order and also issued a demand notice. Procedure followed by the ACIT is contrary to law and mistake could not be cured under section 292B of the Act. Notice is issued in SLP filed by the Revenue (AY. 2011-12 to 2013-14)
CIT v. Cisco Systems services B.V (2024) 297 Taxman 399 (SC) Editorial : CIT (IT) v. Cisco Systems services B.V. (2023) 456 ITR 50/ 293 Taxman 85/334 CTR 52 (Karn)(HC)
S. 144C : Reference to dispute resolution panel-Draft assessment order-Passing of final order-Contrary to law-Mistake could not be cured-Notice is issued in SLP filed by the Revenue [S. 156, 292B, Art. 136]