Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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