TPA - Jurisdiction of the AO in making the assessment without ...

Case Laws Income Tax

May 14, 2015

TPA - Jurisdiction of the AO in making the assessment without referring the matter to the Transfer Pricing Officer where the value of international transactions exceeded ₹ 5 crores - Transfer Pricing adjustments made by the AO in contradiction to the mandatory instructions of the CBDT is bad in law.- AT

View Source

← Previous Next →

TPA - Jurisdiction of the AO in making the assessment without ...

Case Laws Income Tax

May 14, 2015

You may also like:

Reopening of assessment u/s 147 - it appears that the AO has recorded to the effect that he could not refer the matter to the Transfer Pricing Officer nor could he...

Validity of Referring the matter to DVO - Additions based on valuation report - The High Court noted that the assessee had filed its return for the relevant assessment...

Reopening of assessment u/s 147 - AO jurisdiction in issuing notice - Once the territorial jurisdiction of respondent no.1 is admitted by the petitioner, there existed...

Revision u/s 263 - Ld. Pr. CIT exercising jurisdiction under section 263 of the Act, directed the AO to make fresh assessment on the issues which were not the subject...

The Principal Commissioner or Commissioner having jurisdiction over transfer pricing matters has been empowered, effective April 1, 2022, to invoke revisionary action...

Transfer of case - Validity of the assessment orders passed by the Additional CIT u/s 143(1) - Lack of inherent jurisdiction - The assessment order has been passed by...

Jurisdiction by AO to suo-moto convert protective assessment into substantive assessment post completion of original assessment proceedings - Once the ld CIT(A) was...

Jurisdiction of AO - originally the jurisdiction to make the assessment over the company was with the DCIT. The assessment order has been passed by the Addl. CIT without...

Change of jurisdiction u/s 127 - As in the present case, the Assessing Officer rejected the objection regarding the jurisdiction and referred the matter to the PCIT to...

Valuation by DVO - addition based on estimated cost disregarding actual cost as per books - applicability of section 142A before amendment - non-rejection of books - AO...

Assessment u/s 144B - National assessment scheme - as argued AO proposed to modify the return filed by the petitioner without issuing the mandatory show-cause notice...

Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

Capital Gain - Transfer u/s 2(47)(v) - assessment year - AO himself has given credit for the amount of capital gains declared for the assessment year 2013-14, while...

TPA - ALP determination - Without complying to the statutory provisions, the Transfer Pricing Officer certainly cannot determine the arm's length price on ad-hoc /...

The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

Quick Updates: