Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
Period of limitation for passing an order - The submission of the learned counsel for the respondent (Revenue) that by participating in the assessment proceeding, the petitioner must be understood to have waived his right to question the impugned proceeding which is otherwise barred by limitation, is unsustainable. Since, limitation relates to jurisdiction which cannot be conferred by consent, waiver or acquiescence. The impugned order being barred by limitation is thus a nullity. - HC
Period of limitation for passing an order - The submission of the learned counsel for the respondent (Revenue) that by participating in the assessment proceeding, the petitioner must be understood to have waived his right to question the impugned proceeding which is otherwise barred by limitation, is unsustainable. Since, limitation relates to jurisdiction which cannot be conferred by consent, waiver or acquiescence. The impugned order being barred by limitation is thus a nullity. - HC
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