Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Notice u/s 143(2) issued by a non-jurisdictional Assessing Officer/Deputy Commissioner is invalid and cannot be cured. The assessment order framed u/s 143(3) based on such an invalid notice is quashed. As per CBDT Instruction No.1/2011, for cases with total income above the specified limit, the notice u/s 143(2) must be issued by the Assistant Commissioner/Deputy Commissioner themselves and cannot be transferred to the Income Tax Officer. Any inherent defect in the jurisdictional notice u/s 143(2) is not curable, rendering the subsequent assessment order invalid.
Notice u/s 143(2) issued by a non-jurisdictional Assessing Officer/Deputy Commissioner is invalid and cannot be cured. The assessment order framed u/s 143(3) based on such an invalid notice is quashed. As per CBDT Instruction No.1/2011, for cases with total income above the specified limit, the notice u/s 143(2) must be issued by the Assistant Commissioner/Deputy Commissioner themselves and cannot be transferred to the Income Tax Officer. Any inherent defect in the jurisdictional notice u/s 143(2) is not curable, rendering the subsequent assessment order invalid.
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