Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Pecuniary jurisdiction over statutory notices under section 143(2) must comply with CBDT instructions allocating cases by returned-income limits. Where an Income-tax Officer issues the notice despite the returned income exceeding that officer's prescribed limit, the defect concerns pecuniary rather than territorial jurisdiction; the territorial-jurisdiction objection rule does not apply. CBDT instructions bind the Department, and issue of a jurisdictional notice by an officer without pecuniary authority is an illegality, not a procedural irregularity capable of validation under section 292BB. The notices and consequential assessment were therefore treated as void from inception and quashed; other grounds remained academic.
Pecuniary jurisdiction over statutory notices under section 143(2) must comply with CBDT instructions allocating cases by returned-income limits. Where an Income-tax Officer issues the notice despite the returned income exceeding that officer's prescribed limit, the defect concerns pecuniary rather than territorial jurisdiction; the territorial-jurisdiction objection rule does not apply. CBDT instructions bind the Department, and issue of a jurisdictional notice by an officer without pecuniary authority is an illegality, not a procedural irregularity capable of validation under section 292BB. The notices and consequential assessment were therefore treated as void from inception and quashed; other grounds remained academic.
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