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Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
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Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
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A scrutiny assessment requires notice under section 143(2) from the jurisdictional Assessing Officer who completes the assessment. The notes state that a notice issued by a different officer does not cure the defect where there is no transfer order under section 127 or CBDT jurisdictional transfer, and the completing officer issues no fresh notice. As such notice is a mandatory condition for a valid assessment, the assessment is without jurisdiction and must be quashed; other grounds then become academic.
A scrutiny assessment requires notice under section 143(2) from the jurisdictional Assessing Officer who completes the assessment. The notes state that a notice issued by a different officer does not cure the defect where there is no transfer order under section 127 or CBDT jurisdictional transfer, and the completing officer issues no fresh notice. As such notice is a mandatory condition for a valid assessment, the assessment is without jurisdiction and must be quashed; other grounds then become academic.
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