Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Impugned notice u/s 148A(b) of the Income Tax Act quashed. HC held that issuing notice u/s 148 to a deceased assessee instead of legal heir u/s 159(2)(b) is invalid and a condition precedent for reopening assessment. Section 159 applies when proceedings initiated during assessee's lifetime, not when assessee died before notice. Relying on Sumit Balkrishna Gupta and Dharamraj, HC ruled Section 292B also inapplicable in such cases. Writ petition allowed.
Impugned notice u/s 148A(b) of the Income Tax Act quashed. HC held that issuing notice u/s 148 to a deceased assessee instead of legal heir u/s 159(2)(b) is invalid and a condition precedent for reopening assessment. Section 159 applies when proceedings initiated during assessee's lifetime, not when assessee died before notice. Relying on Sumit Balkrishna Gupta and Dharamraj, HC ruled Section 292B also inapplicable in such cases. Writ petition allowed.
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