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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT quashed penalty proceedings under section 270A initiated against deceased assessee ab-initio. Despite receiving notice of assessee's death from legal heir on 28.05.2021, Assessing Officer proceeded to pass penalty order on 26.08.2021 against the deceased person. Tribunal held that once death was brought to AO's knowledge, legal heir should have been brought on record before passing any order. Court established that no order can be validly passed against deceased person under settled legal principle. CIT(A)'s direction was set aside, AO's penalty order was cancelled, and assessee's appeal was allowed, rendering the entire penalty proceedings void from inception.
ITAT quashed penalty proceedings under section 270A initiated against deceased assessee ab-initio. Despite receiving notice of assessee's death from legal heir on 28.05.2021, Assessing Officer proceeded to pass penalty order on 26.08.2021 against the deceased person. Tribunal held that once death was brought to AO's knowledge, legal heir should have been brought on record before passing any order. Court established that no order can be validly passed against deceased person under settled legal principle. CIT(A)'s direction was set aside, AO's penalty order was cancelled, and assessee's appeal was allowed, rendering the entire penalty proceedings void from inception.
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