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 upheld that the assessee's challenge to the territorial jurisdiction of the AO was barred by Section 124(3)(a) of the IT Act because no objection was raised within the statutory period or prior to completion of assessment; notice under s.143(2) served on the PAN address did not revive the objection. The court further held that subsequent administrative reallocation of wards lawfully vested jurisdiction in ITO, Ward-2(1), Raipur, rendering the jurisdictional plea untimely and without merit. Consequently, the ITAT's refusal to entertain the jurisdictional challenge was affirmed and the substantial question of law was answered against the assessee.
The HC upheld that the assessee's challenge to the territorial jurisdiction of the AO was barred by Section 124(3)(a) of the IT Act because no objection was raised within the statutory period or prior to completion of assessment; notice under s.143(2) served on the PAN address did not revive the objection. The court further held that subsequent administrative reallocation of wards lawfully vested jurisdiction in ITO, Ward-2(1), Raipur, rendering the jurisdictional plea untimely and without merit. Consequently, the ITAT's refusal to entertain the jurisdictional challenge was affirmed and the substantial question of law was answered against the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
