Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Penalty u/s 271(1)(c) - An order in the name of dead person - The Appellate Tribunal acknowledged that the penalty order was indeed issued in the name of a deceased assessee. Despite being informed about the death of the assessee, the CIT(A) failed to consider this fact and passed the order in the name of the deceased person. Citing relevant legal precedents, the Tribunal concluded that penalty orders cannot be passed on deceased individuals and that notices should be issued to their legal heirs. Therefore, the Tribunal quashed the penalty order issued by the CIT(A).
Penalty u/s 271(1)(c) - An order in the name of dead person - The Appellate Tribunal acknowledged that the penalty order was indeed issued in the name of a deceased assessee. Despite being informed about the death of the assessee, the CIT(A) failed to consider this fact and passed the order in the name of the deceased person. Citing relevant legal precedents, the Tribunal concluded that penalty orders cannot be passed on deceased individuals and that notices should be issued to their legal heirs. Therefore, the Tribunal quashed the penalty order issued by the CIT(A).
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