Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Reopening of assessment u/s 147 - When the issue is a jurisdictional one, the provisions of Section 292BB of the Act cannot cure jurisdictional error. On perusal of the appellate order, it is also clear that the CIT(A) has discussed the jurisdictional issue raised by the assessee, however, he has rejected the contention of the assessee, which in our opinion, amounts to overruling the CBDT Instruction issued in this regard. - AT
Reopening of assessment u/s 147 - When the issue is a jurisdictional one, the provisions of Section 292BB of the Act cannot cure jurisdictional error. On perusal of the appellate order, it is also clear that the CIT(A) has discussed the jurisdictional issue raised by the assessee, however, he has rejected the contention of the assessee, which in our opinion, amounts to overruling the CBDT Instruction issued in this regard. - AT
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