Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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The ITAT held that the assessment framed by the ITO-2(1), Raipur under section 143(3) was without valid jurisdiction as no valid transfer order under section 127 was passed by the competent authority. The notice under section 143(2) was issued by ITO-1(1), Raipur, creating ambiguity and denying the assessee a fair opportunity to defend. The Tribunal emphasized that any ambiguity in hearing notices preventing effective defense renders the proceedings arbitrary and invalid. Consequently, the assessment order dated 28.12.2019 was quashed for lack of jurisdiction and non-compliance with statutory requirements. The assessee's appeal was allowed.
The ITAT held that the assessment framed by the ITO-2(1), Raipur under section 143(3) was without valid jurisdiction as no valid transfer order under section 127 was passed by the competent authority. The notice under section 143(2) was issued by ITO-1(1), Raipur, creating ambiguity and denying the assessee a fair opportunity to defend. The Tribunal emphasized that any ambiguity in hearing notices preventing effective defense renders the proceedings arbitrary and invalid. Consequently, the assessment order dated 28.12.2019 was quashed for lack of jurisdiction and non-compliance with statutory requirements. The assessee's appeal was allowed.
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