Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
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...
Reopening proceedings against non-existent entity/ partnership firm -The case revolves around the jurisdictional issue arising from actions taken by the assessing officer against a dissolved partnership firm. Despite the firm's amalgamation with a private limited company, the assessing officer proceeded with notices alleging non-filing of income tax returns. The petitioner challenged these actions, arguing that they were without jurisdiction since the partnership firm no longer existed. The High Court agreed with the petitioner, emphasizing that once an entity ceases to exist, no further actions can be initiated against it. It criticized the assessing officer for passing orders without proper consideration and quashed the notices issued against the petitioner.
Reopening proceedings against non-existent entity/ partnership firm -The case revolves around the jurisdictional issue arising from actions taken by the assessing officer against a dissolved partnership firm. Despite the firm's amalgamation with a private limited company, the assessing officer proceeded with notices alleging non-filing of income tax returns. The petitioner challenged these actions, arguing that they were without jurisdiction since the partnership firm no longer existed. The High Court agreed with the petitioner, emphasizing that once an entity ceases to exist, no further actions can be initiated against it. It criticized the assessing officer for passing orders without proper consideration and quashed the notices issued against the petitioner.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
