https://www.taxtmi.com/caselaws?id=439049 A reference to the Transfer Pricing Officer is permissible only in the course of pending scrutiny assessment, because arm's length price determination forms part of assessment of total income. Where no notice under section 143(2) was issued and no scrutiny proceedings were pending, the reference was without jurisdiction and the Transfer Pricing Officer's order was a nullity. An assessment reopening based solely on such an invalid order could not rest on valid material to form a belief that income had escaped assessment, so the reopening was held invalid. en-us Wed, 07 Jun 2023 00:00:00 +0530 Fri, 11 Aug 2023 10:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439049 A reference to the Transfer Pricing Officer is permissible only in the course of pending scrutiny assessment, because arm's length price determination forms part of assessment of total income. Where no notice under section 143(2) was issued and no scrutiny proceedings were pending, the reference was without jurisdiction and the Transfer Pricing Officer's order was a nullity. An assessment reopening based solely on such an invalid order could not rest on valid material to form a belief that income had escaped assessment, so the reopening was held invalid. Case-Laws Income Tax Wed, 07 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439049