Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Non-jurisdictional AO proceeding with the assessment - decentralization of a case after centralization of case - absence of any order of transfer u/s 127 - The court noted the absence of a traceable transfer order u/s 127 despite claims of its existence on the ITBA system. The court emphasized that jurisdiction cannot be assumed without a formal transfer order, which aligns with the intent of Section 127 to facilitate administrative convenience and uphold the public interest. The High Court set aside the assessment orders passed by ITO Ward 21(1) due to the jurisdictional error, underscoring that no valid transfer u/s 127 had been documented.
Non-jurisdictional AO proceeding with the assessment - decentralization of a case after centralization of case - absence of any order of transfer u/s 127 - The court noted the absence of a traceable transfer order u/s 127 despite claims of its existence on the ITBA system. The court emphasized that jurisdiction cannot be assumed without a formal transfer order, which aligns with the intent of Section 127 to facilitate administrative convenience and uphold the public interest. The High Court set aside the assessment orders passed by ITO Ward 21(1) due to the jurisdictional error, underscoring that no valid transfer u/s 127 had been documented.
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