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...
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The HC held that issuance of a show cause notice (SCN) to a deceased proprietor of a firm is impermissible, as section 93 contemplates liability only when the business continues or is discontinued post-death, and mandates issuance of notice to the legal representative. The provision does not authorize determination or recovery against a deceased individual. In the present case, since the SCN and determination were issued against the deceased without involving the legal representative, the actions were invalid. Consequently, the petition was allowed, and the determination against the deceased proprietor was set aside.
The HC held that issuance of a show cause notice (SCN) to a deceased proprietor of a firm is impermissible, as section 93 contemplates liability only when the business continues or is discontinued post-death, and mandates issuance of notice to the legal representative. The provision does not authorize determination or recovery against a deceased individual. In the present case, since the SCN and determination were issued against the deceased without involving the legal representative, the actions were invalid. Consequently, the petition was allowed, and the determination against the deceased proprietor was set aside.
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