Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
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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