Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The High Court held that there is no statutory obligation on legal representatives to immediately inform about the death of an assessee or cancel the PAN registration. If the Department becomes aware of an assessee's death after issuing a notice, there must be a mechanism to recall such notice as serving it on a deceased person would be futile. The legal heirs cannot respond unless served with a notice. The Court quashed the impugned notice for being issued to a deceased person.
The High Court held that there is no statutory obligation on legal representatives to immediately inform about the death of an assessee or cancel the PAN registration. If the Department becomes aware of an assessee's death after issuing a notice, there must be a mechanism to recall such notice as serving it on a deceased person would be futile. The legal heirs cannot respond unless served with a notice. The Court quashed the impugned notice for being issued to a deceased person.
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