Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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CBDT Instruction No. 1 of 2011 issued under section 119 was held to govern pecuniary jurisdiction for issuance of notice under section 143(2). As the assessee's declared income fell below the limit placing jurisdiction with the Income Tax Officer in a metro city, the ACIT lacked competent pecuniary jurisdiction to assume assessment jurisdiction under section 143(3). The defect was treated as a foundational jurisdictional error, not a mere issue of concurrent jurisdiction. The Tribunal distinguished the Revenue's reliance on a different High Court ruling concerning search-related and territorial jurisdiction. The assessment was therefore vitiated and quashed, and the assessee's additional ground was allowed.
CBDT Instruction No. 1 of 2011 issued under section 119 was held to govern pecuniary jurisdiction for issuance of notice under section 143(2). As the assessee's declared income fell below the limit placing jurisdiction with the Income Tax Officer in a metro city, the ACIT lacked competent pecuniary jurisdiction to assume assessment jurisdiction under section 143(3). The defect was treated as a foundational jurisdictional error, not a mere issue of concurrent jurisdiction. The Tribunal distinguished the Revenue's reliance on a different High Court ruling concerning search-related and territorial jurisdiction. The assessment was therefore vitiated and quashed, and the assessee's additional ground was allowed.
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