Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
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Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
HC ruled that the transfer of jurisdiction under Section 127 was improper due to lack of agreement between tax authorities. The search operations at petitioner's premises in 2019, with subsequent assessment orders passed against the party, did not substantiate compelling reasons for jurisdictional transfer. The court quashed the transfer notifications and remitted the cases back to the original Commissioner of Income Tax (Exemptions), directing fresh orders within three months. The petitioners were granted an opportunity to be heard, with consideration of potential loss of faceless assessment benefits under Section 144B of the Income Tax Act.
HC ruled that the transfer of jurisdiction under Section 127 was improper due to lack of agreement between tax authorities. The search operations at petitioner's premises in 2019, with subsequent assessment orders passed against the party, did not substantiate compelling reasons for jurisdictional transfer. The court quashed the transfer notifications and remitted the cases back to the original Commissioner of Income Tax (Exemptions), directing fresh orders within three months. The petitioners were granted an opportunity to be heard, with consideration of potential loss of faceless assessment benefits under Section 144B of the Income Tax Act.
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