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 HC quashed the notice issued u/s 143(2) by the JAO for AY 2023-24, holding that the JAO lacked jurisdiction. As per section 144B(1)(iii), for scrutiny assessment under the Faceless Assessment Scheme, the notice u/s 143(2) is to be issued by the NFAC, not the JAO. The JAO can issue such notice only where notice u/s 148 has already been issued for that AY, which was not the case here. Mere approval from the Pr. CIT cannot confer jurisdiction on the JAO to issue the impugned notice.
The HC quashed the notice issued u/s 143(2) by the JAO for AY 2023-24, holding that the JAO lacked jurisdiction. As per section 144B(1)(iii), for scrutiny assessment under the Faceless Assessment Scheme, the notice u/s 143(2) is to be issued by the NFAC, not the JAO. The JAO can issue such notice only where notice u/s 148 has already been issued for that AY, which was not the case here. Mere approval from the Pr. CIT cannot confer jurisdiction on the JAO to issue the impugned notice.
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