Held that under the Explanatory Memorandum to the Finance Bill, 2020, the amendment to include non-residents as eligible assessees with effect from April 1, 2020 mentioned that if the Assessing Officer proposed to make any variation after this date, in the case of an eligible assessee, which was prejudicial to the interest of the assessee, the above provision shall be applicable. This would mean that all pending assessments for which orders were passed after April 1, 2020 would get covered by the amended section of 144C of the Income-tax Act, 1961 whereby the non-residents would be eligible assessees for taking up the Dispute Resolution Panel route. On the facts the Assessing Officer had issued the draft assessment order on September 27, 2021 and accordingly the amended provisions of section 144C would become applicable.(AY.2019-20)