Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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