Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Reassessment initiation against a deceased assessee is jurisdictionally defective where the show-cause notice is issued after death. Service of a show-cause notice is a condition precedent to an order under Section 148A(3) and a reassessment notice under Section 148; a notice issued to a dead person is non-est and cannot be cured through later proceedings against the legal representative. Section 159 requires reassessment proceedings concerning a deceased person's income to be instituted against the legal representative and does not validate proceedings begun against the deceased, particularly where the Department knew of the death. Participation after a jurisdictional objection does not confer jurisdiction. Consequential proceedings may be quashed, without barring fresh lawful proceedings within limitation.
Reassessment initiation against a deceased assessee is jurisdictionally defective where the show-cause notice is issued after death. Service of a show-cause notice is a condition precedent to an order under Section 148A(3) and a reassessment notice under Section 148; a notice issued to a dead person is non-est and cannot be cured through later proceedings against the legal representative. Section 159 requires reassessment proceedings concerning a deceased person's income to be instituted against the legal representative and does not validate proceedings begun against the deceased, particularly where the Department knew of the death. Participation after a jurisdictional objection does not confer jurisdiction. Consequential proceedings may be quashed, without barring fresh lawful proceedings within limitation.
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