Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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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