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...
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Assessment jurisdiction depends on a valid statutory transfer where scrutiny proceedings move between Assessing Officers. An administrative proforma, without a transfer order under section 127, does not confer jurisdiction on the successor officer, even where that officer has pecuniary jurisdiction. Scrutiny notice validity also depends on service within six months from the end of the financial year in which the return is furnished under section 143(2). A notice issued after that period cannot be treated as valid merely because proceedings were administratively transferred. These requirements determine whether assessment proceedings can be sustained.
Assessment jurisdiction depends on a valid statutory transfer where scrutiny proceedings move between Assessing Officers. An administrative proforma, without a transfer order under section 127, does not confer jurisdiction on the successor officer, even where that officer has pecuniary jurisdiction. Scrutiny notice validity also depends on service within six months from the end of the financial year in which the return is furnished under section 143(2). A notice issued after that period cannot be treated as valid merely because proceedings were administratively transferred. These requirements determine whether assessment proceedings can be sustained.
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