Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
