Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Jurisdiction powers to issue Reopening notice in metro city - It was established that the notice under Section 148 of the Act was issued by an Income Tax Officer (ITO), whereas the jurisdiction allegedly lay with the Assistant Commissioner or Deputy Commissioner of Income Tax. The Tribunal referred to relevant instructions indicating the appropriate jurisdiction based on income levels. Relying on the decision of the Hon'ble Bombay High Court in a similar case, the Tribunal held that the notice issued by the ITO was without jurisdiction and thus rendered the assessment order invalid.
Jurisdiction powers to issue Reopening notice in metro city - It was established that the notice under Section 148 of the Act was issued by an Income Tax Officer (ITO), whereas the jurisdiction allegedly lay with the Assistant Commissioner or Deputy Commissioner of Income Tax. The Tribunal referred to relevant instructions indicating the appropriate jurisdiction based on income levels. Relying on the decision of the Hon'ble Bombay High Court in a similar case, the Tribunal held that the notice issued by the ITO was without jurisdiction and thus rendered the assessment order invalid.
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