Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Powers conferred to CIT(A) u/s 251 - CIT(A) power to direct the AO for issuance of notice u/s 148 - In the present case, Ld.CIT(A) annulled the assessment and further directed to issue notice u/s 148 of the Act. No such power has been granted by the Act, therefore, the impugned direction of Ld.CIT(A) in excess of the jurisdiction conferred by section 251 of the Act, hence the same is set aside. - AT
Powers conferred to CIT(A) u/s 251 - CIT(A) power to direct the AO for issuance of notice u/s 148 - In the present case, Ld.CIT(A) annulled the assessment and further directed to issue notice u/s 148 of the Act. No such power has been granted by the Act, therefore, the impugned direction of Ld.CIT(A) in excess of the jurisdiction conferred by section 251 of the Act, hence the same is set aside. - AT
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