Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
A notice under section 143(2) issued by an Income-tax Officer without pecuniary jurisdiction was held invalid because the assessee's returned income placed the case within the jurisdiction of the AC/DC under CBDT Instruction No. 1/2011. The Tribunal held that the defect went to the root of the scrutiny proceedings and could not be cured by later handling of the case by another officer. The consequential assessment was therefore quashed, and the Revenue's appeal became infructuous.
A notice under section 143(2) issued by an Income-tax Officer without pecuniary jurisdiction was held invalid because the assessee's returned income placed the case within the jurisdiction of the AC/DC under CBDT Instruction No. 1/2011. The Tribunal held that the defect went to the root of the scrutiny proceedings and could not be cured by later handling of the case by another officer. The consequential assessment was therefore quashed, and the Revenue's appeal became infructuous.
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