https://www.taxtmi.com/caselaws?id=431288 Reopening of assessment and transfer pricing procedure require formal assumption of jurisdiction by the assessing officer, which is activated only upon issuance of the statutory notice under Section 143(2); failure to issue that notice vitiates subsequent steps including reference to the transfer pricing officer, and such steps are quashed. CBDT Instruction clarifies that jurisdiction must be assumed before taking assessment actions. Periods during which the file awaited compliance with internal procedure may be excluded when computing the six-month limitation only where statutory explanations to the limitation apply; unreasonable delay in seeking and disposing objections cannot expand the statutory limitation. en-us Wed, 16 Nov 2022 00:00:00 +0530 Wed, 28 Jan 2026 14:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431288 Reopening of assessment and transfer pricing procedure require formal assumption of jurisdiction by the assessing officer, which is activated only upon issuance of the statutory notice under Section 143(2); failure to issue that notice vitiates subsequent steps including reference to the transfer pricing officer, and such steps are quashed. CBDT Instruction clarifies that jurisdiction must be assumed before taking assessment actions. Periods during which the file awaited compliance with internal procedure may be excluded when computing the six-month limitation only where statutory explanations to the limitation apply; unreasonable delay in seeking and disposing objections cannot expand the statutory limitation. Case-Laws Income Tax Wed, 16 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431288