Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
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Transfer of jurisdiction from Faridabad to Delhi was held invalid because the assessee was not given a reasonable opportunity of being heard before the transfer order was made. Notices under section 143(2) issued by Delhi officers were therefore treated as without valid jurisdiction and ineffective for the assessment year concerned. After the transfer order was cancelled, jurisdiction reverted to the original Assessing Officer at Faridabad, but that officer also completed the assessment without first issuing a valid section 143(2) notice. The assessment was consequently quashed for a foundational jurisdictional defect, and the merits were left undecided.
Transfer of jurisdiction from Faridabad to Delhi was held invalid because the assessee was not given a reasonable opportunity of being heard before the transfer order was made. Notices under section 143(2) issued by Delhi officers were therefore treated as without valid jurisdiction and ineffective for the assessment year concerned. After the transfer order was cancelled, jurisdiction reverted to the original Assessing Officer at Faridabad, but that officer also completed the assessment without first issuing a valid section 143(2) notice. The assessment was consequently quashed for a foundational jurisdictional defect, and the merits were left undecided.
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