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...
Validity of faceless assessment challenged due to non-compliance with Section 151A - notices issued by Joint Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO). High Court held that JAO lacked jurisdiction to issue notices u/s 148, particularly in view of Section 151A read with Central Government notification dated 29 March 2022. Relying on Hexaware Technologies Ltd. case, the Court ruled the impugned notices illegal and invalid as JAO had no jurisdiction. Petition allowed in favor of assessee.
Validity of faceless assessment challenged due to non-compliance with Section 151A - notices issued by Joint Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO). High Court held that JAO lacked jurisdiction to issue notices u/s 148, particularly in view of Section 151A read with Central Government notification dated 29 March 2022. Relying on Hexaware Technologies Ltd. case, the Court ruled the impugned notices illegal and invalid as JAO had no jurisdiction. Petition allowed in favor of assessee.
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