Article 227 review permits intervention in arbitration only for manifest, patent inherent jurisdictional defects, not representational authority dispu...
Section 170A(2)(a) limits a modified return filed after business...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer-pricing proceedings.
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Section 170A(2)(a) limits a modified return filed after business reorganisation, where assessment or reassessment had already concluded, to adjusting total income to implement the reorganisation. It does not permit the modified return to be treated as a return under section 139 or to initiate fresh scrutiny under section 143(2); information may be sought only to verify implementation. Transfer-pricing jurisdiction initiated on the premise of valid pending scrutiny does not survive if that scrutiny notice lacks authority. A writ challenging the assumption of statutory jurisdiction remains maintainable despite assessment participation or an appellate remedy. The scrutiny and consequential transfer-pricing proceedings were quashed.
Section 170A(2)(a) limits a modified return filed after business reorganisation, where assessment or reassessment had already concluded, to adjusting total income to implement the reorganisation. It does not permit the modified return to be treated as a return under section 139 or to initiate fresh scrutiny under section 143(2); information may be sought only to verify implementation. Transfer-pricing jurisdiction initiated on the premise of valid pending scrutiny does not survive if that scrutiny notice lacks authority. A writ challenging the assumption of statutory jurisdiction remains maintainable despite assessment participation or an appellate remedy. The scrutiny and consequential transfer-pricing proceedings were quashed.
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