Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Section 142(1) notice issued by non-jurisdictional officer held valid. Plain reading of Section 143(2) indicates either Assessing Officer or prescribed income-tax authority can issue notice u/s 143(2). CBDT notification authorized Assistant/Deputy Commissioner to act as prescribed authority for issuing Section 143(2) notice. Contention that only NaFAC officers can issue notice unmerited, not supported by provisions. Prescribed authority can issue, not just serve, Section 143(2) notice. Assessing Officer had jurisdiction to issue impugned Section 142(1) notice, not barred by limitation. Once Section 143(2) jurisdiction established, Assessing Officer cannot be faulted for completing assessment.
Section 142(1) notice issued by non-jurisdictional officer held valid. Plain reading of Section 143(2) indicates either Assessing Officer or prescribed income-tax authority can issue notice u/s 143(2). CBDT notification authorized Assistant/Deputy Commissioner to act as prescribed authority for issuing Section 143(2) notice. Contention that only NaFAC officers can issue notice unmerited, not supported by provisions. Prescribed authority can issue, not just serve, Section 143(2) notice. Assessing Officer had jurisdiction to issue impugned Section 142(1) notice, not barred by limitation. Once Section 143(2) jurisdiction established, Assessing Officer cannot be faulted for completing assessment.
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