SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Validity of a scrutiny assessment depends on issuance of a valid notice under section 143(2) within the prescribed limitation period; a notice issued after that period cannot support an assessment under section 143(3). Assessment jurisdiction following transfer of proceedings also requires a valid transfer order under section 127. Statutory powers must be exercised by the authority designated by law, and failure to produce a valid transfer order leaves the officer completing the assessment without jurisdiction. These defects render the assessment void ab initio.
Validity of a scrutiny assessment depends on issuance of a valid notice under section 143(2) within the prescribed limitation period; a notice issued after that period cannot support an assessment under section 143(3). Assessment jurisdiction following transfer of proceedings also requires a valid transfer order under section 127. Statutory powers must be exercised by the authority designated by law, and failure to produce a valid transfer order leaves the officer completing the assessment without jurisdiction. These defects render the assessment void ab initio.
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