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...
A jurisdictional objection going to the root of assessment authority was allowed as an additional ground because it raised a pure question of law on admitted facts. Since no order transferring jurisdiction under Section 127 had been passed, transfer from one Assessing Officer to another could not be presumed and the assessment proceedings were rendered without valid authority. The Tribunal therefore admitted the additional ground and quashed the assessment as void for lack of jurisdiction.
A jurisdictional objection going to the root of assessment authority was allowed as an additional ground because it raised a pure question of law on admitted facts. Since no order transferring jurisdiction under Section 127 had been passed, transfer from one Assessing Officer to another could not be presumed and the assessment proceedings were rendered without valid authority. The Tribunal therefore admitted the additional ground and quashed the assessment as void for lack of jurisdiction.
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