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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
HC held that reassessment proceedings under s147 initiated against a deceased assessee through notice issued post-death cannot be continued against legal representatives (LRs). While ongoing proceedings initiated during an assessee's lifetime may continue against LRs under s159(2)(b), new proceedings cannot commence after death. The court rejected Revenue's request for liberty to initiate fresh proceedings against LRs, noting no statutory obligation exists for LRs to inform Revenue about assessee's death. Additionally, if the limitation period for proceedings expired against the deceased, no action can be taken against LRs. The Income Tax Act 1961 contains no provision to exclude time spent during proceedings against deceased when calculating limitation period for LR proceedings. Appeal dismissed.
HC held that reassessment proceedings under s147 initiated against a deceased assessee through notice issued post-death cannot be continued against legal representatives (LRs). While ongoing proceedings initiated during an assessee's lifetime may continue against LRs under s159(2)(b), new proceedings cannot commence after death. The court rejected Revenue's request for liberty to initiate fresh proceedings against LRs, noting no statutory obligation exists for LRs to inform Revenue about assessee's death. Additionally, if the limitation period for proceedings expired against the deceased, no action can be taken against LRs. The Income Tax Act 1961 contains no provision to exclude time spent during proceedings against deceased when calculating limitation period for LR proceedings. Appeal dismissed.
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