Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Notices issued by Jurisdictional Assessing Officer (JAO) u/s 148 instead of Faceless Assessment Officer (FAO) are invalid after introduction of Finance Act 2021. Scheme of faceless assessment applies from notice stage u/ss 148 and 148A as per notification u/s 151A. Assessment proceedings commence from issuance of show cause notice. Allowing JAO to issue notice would defeat faceless assessment objective. Departmental circulars cannot override statutory provisions; courts are not bound by them. Circulars supplement but cannot supplant statutory provisions. Notices issued by JAO u/s 148 quashed; liberty granted to proceed as per prescribed procedure.
Notices issued by Jurisdictional Assessing Officer (JAO) u/s 148 instead of Faceless Assessment Officer (FAO) are invalid after introduction of Finance Act 2021. Scheme of faceless assessment applies from notice stage u/ss 148 and 148A as per notification u/s 151A. Assessment proceedings commence from issuance of show cause notice. Allowing JAO to issue notice would defeat faceless assessment objective. Departmental circulars cannot override statutory provisions; courts are not bound by them. Circulars supplement but cannot supplant statutory provisions. Notices issued by JAO u/s 148 quashed; liberty granted to proceed as per prescribed procedure.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
