Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
Assessment issued in the name of an amalgamating company that had ceased to exist, after the Revenue had been informed of the amalgamation, constitutes a jurisdictional defect rather than a procedural irregularity. Section 292B does not cure this defect, and participation in assessment proceedings does not create an estoppel against law. The assessment was quashed as void ab initio on the additional jurisdictional ground, while the remaining merits grounds were left open as academic.
Assessment issued in the name of an amalgamating company that had ceased to exist, after the Revenue had been informed of the amalgamation, constitutes a jurisdictional defect rather than a procedural irregularity. Section 292B does not cure this defect, and participation in assessment proceedings does not create an estoppel against law. The assessment was quashed as void ab initio on the additional jurisdictional ground, while the remaining merits grounds were left open as academic.
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