Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
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Pecuniary jurisdiction limits under the applicable CBDT instruction required reassessment of a non-corporate assessee in a mofussil area exceeding the prescribed limit to be handled by an Assistant or Deputy Commissioner, rather than an Income-tax Officer. As the reassessment notice was issued by an officer lacking that jurisdiction and the defect was unrebutted, the notice was inherently invalid. The consequential assessment was quashed as void ab initio, rendering the remaining grounds academic.
Pecuniary jurisdiction limits under the applicable CBDT instruction required reassessment of a non-corporate assessee in a mofussil area exceeding the prescribed limit to be handled by an Assistant or Deputy Commissioner, rather than an Income-tax Officer. As the reassessment notice was issued by an officer lacking that jurisdiction and the defect was unrebutted, the notice was inherently invalid. The consequential assessment was quashed as void ab initio, rendering the remaining grounds academic.
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