Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
Under CBDT Instruction No. 1/2011, metro corporate returns up to the prescribed income limit remained with the ITO, while only higher-value cases fell within ACIT/DCIT jurisdiction. Because the assessee's returned income and income assessed under section 143(3) were both below that limit, the ACIT lacked monetary jurisdiction to issue the section 148 notice. The Tribunal treated this defect as going to the validity of the jurisdictional notice itself, held the notice invalid, and quashed the reassessment order as consequentially unsustainable.
Under CBDT Instruction No. 1/2011, metro corporate returns up to the prescribed income limit remained with the ITO, while only higher-value cases fell within ACIT/DCIT jurisdiction. Because the assessee's returned income and income assessed under section 143(3) were both below that limit, the ACIT lacked monetary jurisdiction to issue the section 148 notice. The Tribunal treated this defect as going to the validity of the jurisdictional notice itself, held the notice invalid, and quashed the reassessment order as consequentially unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
