Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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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