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...
A notice under section 143(2) issued by the officer who completes a scrutiny assessment under section 143(3) is presented as a mandatory jurisdictional requirement. The notes state that where one officer issued the statutory notice but another completed the assessment without issuing a fresh notice, the assessment has an inherent jurisdictional defect rather than a curable procedural irregularity. Relying on the stated Delhi High Court and Supreme Court positions, the text explains that such an assessment is invalid, consequential proceedings are non est, and other grounds become academic.
A notice under section 143(2) issued by the officer who completes a scrutiny assessment under section 143(3) is presented as a mandatory jurisdictional requirement. The notes state that where one officer issued the statutory notice but another completed the assessment without issuing a fresh notice, the assessment has an inherent jurisdictional defect rather than a curable procedural irregularity. Relying on the stated Delhi High Court and Supreme Court positions, the text explains that such an assessment is invalid, consequential proceedings are non est, and other grounds become academic.
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