Sec. 92CA of Income Tax Act, 1961—Transfer Pricing—Merely by issuing a corrigendum, final assessment order passed cannot be converted into a draft assessment order especially when such corrigendum has been passed beyond the period of limitation and if the draft assessment order has not been passed in accordance with the procedure laid down in Section 144C (1) and instead final assessment order has been passed though within the limitation time, then such an order cannot be cured after the limitation has expired by any subsequent rectification proceedings or corrigendum and in such a situation all the subsequent proceedings and final assessment order will get invalidated, therefore, it was held that the proposed corrigendum issued by the Assessing Officer so as to cure the defect of the original final assessment order is bad in law and same could not have been done and consequently entire subsequent proceedings and final assessment order is held to be invalid being barred by limitation and is hereby quashed—NORTH SHORE TECHNOLOGIES PVT. LTD. Vs. ITO [2020] 78 ITR (TRIB) 204 (ITAT-DELHI)