Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Tax liability of a deceased sole proprietor may be enforced against the legal representatives to the extent of the estate, and death does not extinguish liability for tax, interest or penalty. The operative safeguard is that any adverse determination must be made only after personal hearing and by a reasoned, speaking order. A demand raised in the name of the deceased without hearing the legal representatives is not sustainable. The source also notes that another challenge was not pressed and was left open.
Tax liability of a deceased sole proprietor may be enforced against the legal representatives to the extent of the estate, and death does not extinguish liability for tax, interest or penalty. The operative safeguard is that any adverse determination must be made only after personal hearing and by a reasoned, speaking order. A demand raised in the name of the deceased without hearing the legal representatives is not sustainable. The source also notes that another challenge was not pressed and was left open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
