Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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.
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