Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
The case discusses the validity of proceedings against the legal representatives of a deceased assessee when reopening notices in the name of the assessee have expired. The court held that legal representatives have the right to contest proceedings and determine the extent of liability. However, in this case, the respondents failed to follow the provisions of Section 159, leading to the set-aside of the reopening notice against the deceased assessee. The court granted liberty to the Revenue to proceed against the legal heirs if permitted by law.
The case discusses the validity of proceedings against the legal representatives of a deceased assessee when reopening notices in the name of the assessee have expired. The court held that legal representatives have the right to contest proceedings and determine the extent of liability. However, in this case, the respondents failed to follow the provisions of Section 159, leading to the set-aside of the reopening notice against the deceased assessee. The court granted liberty to the Revenue to proceed against the legal heirs if permitted by law.
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