Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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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