Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Jurisdictional defect in an assessment may be raised in collateral penalty proceedings where the assessment was made without a valid notice under section 143(2) from the jurisdictional Assessing Officer. An order made without jurisdiction is a nullity and may be challenged whenever enforcement or reliance is attempted, notwithstanding that the assessment has attained finality. Because the assessment was invalid and non est, the consequential penalty order was quashed.
Jurisdictional defect in an assessment may be raised in collateral penalty proceedings where the assessment was made without a valid notice under section 143(2) from the jurisdictional Assessing Officer. An order made without jurisdiction is a nullity and may be challenged whenever enforcement or reliance is attempted, notwithstanding that the assessment has attained finality. Because the assessment was invalid and non est, the consequential penalty order was quashed.
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