Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
After transfer of the assessee's jurisdiction from Ajmer to Mumbai under section 127, the earlier Assessing Officer became functus officio and lacked authority to issue the reassessment notice or complete assessment. The Tribunal held that valid assumption of jurisdiction is a condition precedent, not a procedural irregularity, so proceedings initiated by an officer without inherent jurisdiction are void ab initio. Accordingly, the reassessment orders for both years were quashed as invalid, and the Revenue's grounds on the merits became academic and infructuous.
After transfer of the assessee's jurisdiction from Ajmer to Mumbai under section 127, the earlier Assessing Officer became functus officio and lacked authority to issue the reassessment notice or complete assessment. The Tribunal held that valid assumption of jurisdiction is a condition precedent, not a procedural irregularity, so proceedings initiated by an officer without inherent jurisdiction are void ab initio. Accordingly, the reassessment orders for both years were quashed as invalid, and the Revenue's grounds on the merits became academic and infructuous.
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