Year-wise GST tax periods make composite show cause notices impermissible, requiring separate proceedings despite contrary non-jurisdictional preceden...
Prior APA methodology guides transfer pricing benchmarking where consistent FAR profiles support comparability and arm's length margins eliminate adju...
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Validity of notice - Reopening of assessment u/s 147 - In the present case, there is an in advertent error in the notice issued by the AO reflecting only the PAN column of the notice mentions PAN of the “HUF” instead of the ‘individual’ whereas the body of the notice and the address shows that the notice is clearly meant for the assessee himself - On going through the Reasons recorded, the address on the notice, the body of the notice issue of notice, we hold that the notice of the Assessing Officer wherein there is a mistake only in the PAN number, the notice is covered by the provisions of Section 292B. - AT
Validity of notice - Reopening of assessment u/s 147 - In the present case, there is an in advertent error in the notice issued by the AO reflecting only the PAN column of the notice mentions PAN of the “HUF” instead of the ‘individual’ whereas the body of the notice and the address shows that the notice is clearly meant for the assessee himself - On going through the Reasons recorded, the address on the notice, the body of the notice issue of notice, we hold that the notice of the Assessing Officer wherein there is a mistake only in the PAN number, the notice is covered by the provisions of Section 292B. - AT
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