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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
