https://www.taxtmi.com/caselaws?id=779143 Where a taxpayer entered into a unilateral Advance Pricing Agreement (APA) and filed the Annual Compliance Report (ACR) within Rule 10O timelines without any adverse finding from the Transfer Pricing Officer (TPO) or CBDT, the Assessing Officer lacked jurisdiction to examine ALP or modify income; only the TPO may conduct the compliance audit and, if adverse, trigger cancellation procedures. Separately, reopening after more than three years required higher authority sanction; the prior approval obtained was defective, rendering the reassessment order void. The notice issued under reassessment provisions was therefore without jurisdiction; Apex Court refused further interference and no stay exists on the High Court order. en-us Thu, 25 Sep 2025 00:00:00 +0530 Fri, 17 Apr 2026 17:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779143 Where a taxpayer entered into a unilateral Advance Pricing Agreement (APA) and filed the Annual Compliance Report (ACR) within Rule 10O timelines without any adverse finding from the Transfer Pricing Officer (TPO) or CBDT, the Assessing Officer lacked jurisdiction to examine ALP or modify income; only the TPO may conduct the compliance audit and, if adverse, trigger cancellation procedures. Separately, reopening after more than three years required higher authority sanction; the prior approval obtained was defective, rendering the reassessment order void. The notice issued under reassessment provisions was therefore without jurisdiction; Apex Court refused further interference and no stay exists on the High Court order. Case-Laws Income Tax Thu, 25 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779143