Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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ITAT invalidated the transfer pricing (TP) order and draft assessment order issued against a non-existent entity. The tribunal held that notices and orders issued under the name and PAN of a non-existing company are illegal and without jurisdiction, rendering the entire assessment proceeding invalid. Relying on Supreme Court precedents, the tribunal found that such errors cannot be cured under Section 292B of the Income Tax Act. Consequently, the assessee's appeal was allowed, quashing the proceedings issued against the non-existent entity and affirming that foundational documents must be valid for a legitimate assessment process.
ITAT invalidated the transfer pricing (TP) order and draft assessment order issued against a non-existent entity. The tribunal held that notices and orders issued under the name and PAN of a non-existing company are illegal and without jurisdiction, rendering the entire assessment proceeding invalid. Relying on Supreme Court precedents, the tribunal found that such errors cannot be cured under Section 292B of the Income Tax Act. Consequently, the assessee's appeal was allowed, quashing the proceedings issued against the non-existent entity and affirming that foundational documents must be valid for a legitimate assessment process.
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