Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Under reassessment procedure, a scrutiny notice must be issued only after the taxpayer files a return in response to a reopening notice. Issuing the scrutiny notice before that return is filed makes the notice invalid and cannot cure the statutory defect. Without a valid scrutiny notice, the reassessment order is invalid. Reassessment orders founded on prematurely issued scrutiny notices are therefore liable to be set aside, and appeals challenging their invalidation fail where no further question of law arises.
Under reassessment procedure, a scrutiny notice must be issued only after the taxpayer files a return in response to a reopening notice. Issuing the scrutiny notice before that return is filed makes the notice invalid and cannot cure the statutory defect. Without a valid scrutiny notice, the reassessment order is invalid. Reassessment orders founded on prematurely issued scrutiny notices are therefore liable to be set aside, and appeals challenging their invalidation fail where no further question of law arises.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
