Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Reopening of assessment u/s 147 - wrong facts in reasons recorded - AO completely ignored the fact that the return was already filed on 18.01.2010 and vide letter dated 24.02.2012 the assessee has explained that he is a regular assessee and produced the copy of Income-tax return filed - assumption of jurisdiction by the AO is bad in law
Reopening of assessment u/s 147 - wrong facts in reasons recorded - AO completely ignored the fact that the return was already filed on 18.01.2010 and vide letter dated 24.02.2012 the assessee has explained that he is a regular assessee and produced the copy of Income-tax return filed - assumption of jurisdiction by the AO is bad in law
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