Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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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