Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Restricted gold import conditions: breach permits absolute confiscation, while redemption remains discretionary and is rarely disturbed on writ review...
ITAT ordinary territorial jurisdiction is determined by the location of the Assessing Officer who issued the assessment order, rather than the assessee's location or that of the Commissioner (Appeals). The President's procedural rule-making power does not extend to transferring a pending appeal between Benches situated in different States. Where the assessment order originated from an Assessing Officer at Chennai, the Mumbai Bench lacked jurisdiction over both the Revenue's appeal and the assessee's related cross-objection. Both were dismissed for want of territorial jurisdiction, with liberty to approach the appropriate Bench; merits remained open.
ITAT ordinary territorial jurisdiction is determined by the location of the Assessing Officer who issued the assessment order, rather than the assessee's location or that of the Commissioner (Appeals). The President's procedural rule-making power does not extend to transferring a pending appeal between Benches situated in different States. Where the assessment order originated from an Assessing Officer at Chennai, the Mumbai Bench lacked jurisdiction over both the Revenue's appeal and the assessee's related cross-objection. Both were dismissed for want of territorial jurisdiction, with liberty to approach the appropriate Bench; merits remained open.
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