Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
After a search under section 132 in the assessee's case, the ITAT held that the Assessing Officer could not continue with a normal scrutiny assessment under section 143(3) and had to proceed under the special post-search statutory route. Because the Revenue did not dislodge this jurisdictional defect, the Tribunal found an invalid assumption of jurisdiction and quashed the assessment framed under section 143(3). The grounds challenging the additions on merits were therefore rendered academic.
After a search under section 132 in the assessee's case, the ITAT held that the Assessing Officer could not continue with a normal scrutiny assessment under section 143(3) and had to proceed under the special post-search statutory route. Because the Revenue did not dislodge this jurisdictional defect, the Tribunal found an invalid assumption of jurisdiction and quashed the assessment framed under section 143(3). The grounds challenging the additions on merits were therefore rendered academic.
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