COVID-19 limitation exclusion and destination-specific e-way bills govern revisional timelines and penalties for undocumented third-party plywood deli...
Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengea...
Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Where CBDT pecuniary-jurisdiction instructions allocate an assessee's case to an ITO, a scrutiny notice issued by an ACIT without a prior transfer order is beyond that officer's jurisdiction. An assessment founded on that notice is invalid and may be quashed without examination of the merits. The same jurisdictional principle applies where a reassessment notice is issued by an authority lacking jurisdiction over the assessee. Proper allocation and transfer of jurisdiction are therefore essential to the validity of income-tax assessment proceedings.
Where CBDT pecuniary-jurisdiction instructions allocate an assessee's case to an ITO, a scrutiny notice issued by an ACIT without a prior transfer order is beyond that officer's jurisdiction. An assessment founded on that notice is invalid and may be quashed without examination of the merits. The same jurisdictional principle applies where a reassessment notice is issued by an authority lacking jurisdiction over the assessee. Proper allocation and transfer of jurisdiction are therefore essential to the validity of income-tax assessment proceedings.
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