On writ the Court held that a draft assessment order having not been passed to enable the assessee to file its objections before the Dispute Resolution Panel, the order in question was to be treated as a draft assessment order and not as an assessment order passed under section 143(3). The assessee was given liberty to file its objections against the draft assessment order before the Dispute Resolution Panel under section 144C and till the disposal of the objections the demand raised would remain stayed. (AY.2019-20)
Criteo Singapore Pte. Ltd. v. CIT (IT) (2022) 440 ITR 242 (Delhi)(HC)
S. 144C : Reference to dispute resolution panel-Foreign Company-Draft Assessment order was not passed-DTAA-India-Singapore-Demand raised was stayed. [S. 143(3), Art. 226]