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Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
Issuance of a notice under section 143(2) is a jurisdictional requirement where a return is filed belatedly in response to an inquiry; absence of that notice renders any assessment completed under section 144 void. The tribunal found no material proving service of the mandatory notice and, following existing precedent, held the assessment without such notice invalid and quashed the assessment order, allowing the taxpayer's appeal.
Issuance of a notice under section 143(2) is a jurisdictional requirement where a return is filed belatedly in response to an inquiry; absence of that notice renders any assessment completed under section 144 void. The tribunal found no material proving service of the mandatory notice and, following existing precedent, held the assessment without such notice invalid and quashed the assessment order, allowing the taxpayer's appeal.
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