Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Validity of reopening notice - Absence of the manual/digital signature of the A.O in the copy of the Reopening notice - Elaborating on the term "signed", it was observed that that same was to be construed as giving one's name to signify assent or adhesion to by signing one's name; to attest by signing or when a person is unable to write his name then affixation of "mark" by such person. - The Tribunal highlighted significant procedural lapses, notably the absence of the Assessing Officer's signature on the notice under section 148, leading to the quashing of the assessment order. The Tribunal's decision underscores the importance of adhering to procedural requirements, emphasizing that such lapses can invalidate otherwise substantive assessments.
Validity of reopening notice - Absence of the manual/digital signature of the A.O in the copy of the Reopening notice - Elaborating on the term "signed", it was observed that that same was to be construed as giving one's name to signify assent or adhesion to by signing one's name; to attest by signing or when a person is unable to write his name then affixation of "mark" by such person. - The Tribunal highlighted significant procedural lapses, notably the absence of the Assessing Officer's signature on the notice under section 148, leading to the quashing of the assessment order. The Tribunal's decision underscores the importance of adhering to procedural requirements, emphasizing that such lapses can invalidate otherwise substantive assessments.
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