Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
Validity of reopening of assessment - jurisdiction of notice issuing authority - A jurisdiction can neither be waived nor created even by consent and even by submitting to jurisdiction, an Assessee cannot confer upon any jurisdictional authority, something which he lacked inherently. Therefore the contention of DR regarding applicability of section 292BB also does not hold water in favour of the revenue. - AT
Validity of reopening of assessment - jurisdiction of notice issuing authority - A jurisdiction can neither be waived nor created even by consent and even by submitting to jurisdiction, an Assessee cannot confer upon any jurisdictional authority, something which he lacked inherently. Therefore the contention of DR regarding applicability of section 292BB also does not hold water in favour of the revenue. - AT
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