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...
The court held that the Joint Assessing Officer (JAO) lacked jurisdiction to issue notices u/s 148 of the Income Tax Act for reassessment, as per Section 151A read with the Central Government notification dated 29 March 2022. This provision mandates that such notices be issued by the Faceless Assessment Officer (FAO). Relying on the Hexaware Technologies Ltd. case, the court concluded that the impugned notices issued by the JAO were illegal and invalid due to lack of jurisdiction. Consequently, the court allowed the petition in favor of the assessee, quashing the reassessment notices.
The court held that the Joint Assessing Officer (JAO) lacked jurisdiction to issue notices u/s 148 of the Income Tax Act for reassessment, as per Section 151A read with the Central Government notification dated 29 March 2022. This provision mandates that such notices be issued by the Faceless Assessment Officer (FAO). Relying on the Hexaware Technologies Ltd. case, the court concluded that the impugned notices issued by the JAO were illegal and invalid due to lack of jurisdiction. Consequently, the court allowed the petition in favor of the assessee, quashing the reassessment notices.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4786
Join Channel
TaxTMI 
