Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
An unsigned notice initiating penalty proceedings under section 274 read with section 271(1)(c) was held invalid because section 282A requires statutory notices to be signed. Printing the authority's name, office, or a DIN did not satisfy that mandatory requirement, and the defect was treated as jurisdictional rather than technical. The assessee's participation and section 292B could not cure the absence of signature, and a later signed reminder notice did not validate the original initiation. As the Assessing Officer never acquired valid jurisdiction to proceed, the consequential reminder notice and penalty order were quashed.
An unsigned notice initiating penalty proceedings under section 274 read with section 271(1)(c) was held invalid because section 282A requires statutory notices to be signed. Printing the authority's name, office, or a DIN did not satisfy that mandatory requirement, and the defect was treated as jurisdictional rather than technical. The assessee's participation and section 292B could not cure the absence of signature, and a later signed reminder notice did not validate the original initiation. As the Assessing Officer never acquired valid jurisdiction to proceed, the consequential reminder notice and penalty order were quashed.
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