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Section 127 transfers for centralised assessment require...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes require statutory appeal.
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Section 127 transfers for centralised assessment require recorded and communicated reasons, and transfers between officers subordinate to different Commissioners require the prescribed inter-Commissioner agreement; an opportunity of hearing depends on feasibility. Taxpayers who requested centralisation, filed returns, responded to notices and participated before the transferee officer were treated as having acquiesced in the transferred jurisdiction, preventing a later technical challenge to the transfer. Challenges to consequential assessment orders were not entertained in writ jurisdiction where an effective statutory appellate remedy was available. The writ petitions challenging the transfers and assessments were dismissed.
Section 127 transfers for centralised assessment require recorded and communicated reasons, and transfers between officers subordinate to different Commissioners require the prescribed inter-Commissioner agreement; an opportunity of hearing depends on feasibility. Taxpayers who requested centralisation, filed returns, responded to notices and participated before the transferee officer were treated as having acquiesced in the transferred jurisdiction, preventing a later technical challenge to the transfer. Challenges to consequential assessment orders were not entertained in writ jurisdiction where an effective statutory appellate remedy was available. The writ petitions challenging the transfers and assessments were dismissed.
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