Held that passing of the draft assessment order as prescribed under section 144C(1) of the Act is mandatory. There is no estoppel against the law. The assessee cannot be estopped from challenging  the assessment order which was passed on the basis of the admission by the assessee itself before DRP. Accordingly the order passed without passing the draft assessment order is bad in law. Appeal of the assessee is allowed.     (AY. 2011-12) (ITA No. 2073/Mum/ 2022 dt. 31-1 2024)