Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Omission of section 92BA(1) without a saving clause rendered the provision nonexistent, therefore any assessment officer reference to the transfer pricing officer to determine the arm's length price of specified domestic transactions lacked jurisdiction and the TPO's consequential order was invalid; the appellate authority has deleted the additions and the revenue appeal was dismissed, applying the principle that where a statutory provision is omitted from the statute book the AO cannot invoke that provision to re open or adjust domestic transfer pricing.
Omission of section 92BA(1) without a saving clause rendered the provision nonexistent, therefore any assessment officer reference to the transfer pricing officer to determine the arm's length price of specified domestic transactions lacked jurisdiction and the TPO's consequential order was invalid; the appellate authority has deleted the additions and the revenue appeal was dismissed, applying the principle that where a statutory provision is omitted from the statute book the AO cannot invoke that provision to re open or adjust domestic transfer pricing.
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