Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Petitioner argued non-receipt of notices preceding impugned assessment orders. Partnership firm discontinued business, carried on by proprietor. Court held petitioner neglected intimating firm's dissolution, surrendering PAN. Transactions made from firm's account despite alleged proprietorship. Returns filed from firm's address. Huge transactions observed. Respondent rightfully passed order u/s 144 read with 147 due to non-reply. Petitioner individually assessed requiring detailed consideration. Court quashed impugned orders, treating them as addenda to show-cause notices. Petitioner to pre-deposit Rs. 50,00,000 within eight weeks to Income Tax Department. Opportunity granted to file reply.
Petitioner argued non-receipt of notices preceding impugned assessment orders. Partnership firm discontinued business, carried on by proprietor. Court held petitioner neglected intimating firm's dissolution, surrendering PAN. Transactions made from firm's account despite alleged proprietorship. Returns filed from firm's address. Huge transactions observed. Respondent rightfully passed order u/s 144 read with 147 due to non-reply. Petitioner individually assessed requiring detailed consideration. Court quashed impugned orders, treating them as addenda to show-cause notices. Petitioner to pre-deposit Rs. 50,00,000 within eight weeks to Income Tax Department. Opportunity granted to file reply.
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