Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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