Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
HC held that Section 93 addresses tax liability post-death but does not authorize determination against a deceased person. Issuance of show cause notice (SCN) and demand against a deceased individual without notifying legal representatives is procedurally invalid. The statutory requirement mandates serving SCN on legal representatives and obtaining their response before initiating any determination proceedings. The impugned order was consequently deemed unsustainable, with the court allowing the petition and invalidating the tax determination against the deceased taxpayer.
HC held that Section 93 addresses tax liability post-death but does not authorize determination against a deceased person. Issuance of show cause notice (SCN) and demand against a deceased individual without notifying legal representatives is procedurally invalid. The statutory requirement mandates serving SCN on legal representatives and obtaining their response before initiating any determination proceedings. The impugned order was consequently deemed unsustainable, with the court allowing the petition and invalidating the tax determination against the deceased taxpayer.
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