Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Reassessment against a dissolved partnership firm after its business succession is void where the Department had accepted that the firm ceased to exist and the successor proprietor disclosed and was assessed on the same business transactions and bank accounts. Assessing the erstwhile firm in these circumstances would duplicate taxation of the same business income. Jurisdiction for reassessment also requires recorded reasons identifying the relevant bank account or transaction and foundational material showing income escaped assessment; vague reasons do not meet that standard. A notice issued to a non-existent entity after succession renders the consequential assessment and estimated addition unsustainable.
Reassessment against a dissolved partnership firm after its business succession is void where the Department had accepted that the firm ceased to exist and the successor proprietor disclosed and was assessed on the same business transactions and bank accounts. Assessing the erstwhile firm in these circumstances would duplicate taxation of the same business income. Jurisdiction for reassessment also requires recorded reasons identifying the relevant bank account or transaction and foundational material showing income escaped assessment; vague reasons do not meet that standard. A notice issued to a non-existent entity after succession renders the consequential assessment and estimated addition unsustainable.
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