Summary
Orpak Systems India declared a loss for AY 2022-23 that was cut after a transfer pricing adjustment, through a final order issued without a draft order under Section 144C. The Bombay High Court set the order aside, treating the skipped draft stage as a jurisdictional defect rather than a curable lapse.
What it means for you
Taxpayers with transfer pricing adjustments can challenge final orders passed without a Section 144C draft, since the bypass denies them the DRP route.
This summary is general information, not legal advice. The outcome of any case depends on its facts; read the source and take advice before acting.
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