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...
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.
Note: It is a system-generated summary and is for quick reference only.