Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
HC held that under Sections 292B and 292BB of the Income Tax Act, the assessee cannot challenge the validity of a notice u/s 143(2) or assessment order u/s 143(3) after appearing in proceedings without raising objections. The procedural defect of not issuing notice by DCIT does not invalidate the assessment, as the notice substantially conforms to the Act's intent. The ITAT's order interfering with the assessment was set aside, affirming the tax authorities' jurisdiction and the assessment's legal validity.
HC held that under Sections 292B and 292BB of the Income Tax Act, the assessee cannot challenge the validity of a notice u/s 143(2) or assessment order u/s 143(3) after appearing in proceedings without raising objections. The procedural defect of not issuing notice by DCIT does not invalidate the assessment, as the notice substantially conforms to the Act's intent. The ITAT's order interfering with the assessment was set aside, affirming the tax authorities' jurisdiction and the assessment's legal validity.
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