Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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Mandatory statutory notice prior to framing an assessment is required even where a return is filed in response to a notice under reassessment proceedings; if the Assessing Officer takes the filed return as the starting point for computation and acts upon it, pending electronic verification or later submission of a manual verification does not alone invalidate the return. An assessment completed without issuing the mandatory notice under the statutory provision governing notice before assessment is a jurisdictional defect and vitiates the assessment framed under reassessment provisions, resulting in the quashing of the assessment for the relevant year.
Mandatory statutory notice prior to framing an assessment is required even where a return is filed in response to a notice under reassessment proceedings; if the Assessing Officer takes the filed return as the starting point for computation and acts upon it, pending electronic verification or later submission of a manual verification does not alone invalidate the return. An assessment completed without issuing the mandatory notice under the statutory provision governing notice before assessment is a jurisdictional defect and vitiates the assessment framed under reassessment provisions, resulting in the quashing of the assessment for the relevant year.
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