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International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
ITAT upheld imposition of penalty under section 271(1)(c) against the deceased's legal representatives, holding that section 159(1) renders legal representatives liable for tax and ancillary sums the deceased would have owed; therefore penalty proceedings can be continued or initiated against them. The bench rejected reliance on the contrary earlier precedent as having been overruled and sustained the penalty. Because the AR could not clarify whether the legal representatives inherited any estate or its extent, the Tribunal remanded the limited issue to the AO to determine the existence and extent of any estate capable of meeting the liability and to proceed accordingly.
ITAT upheld imposition of penalty under section 271(1)(c) against the deceased's legal representatives, holding that section 159(1) renders legal representatives liable for tax and ancillary sums the deceased would have owed; therefore penalty proceedings can be continued or initiated against them. The bench rejected reliance on the contrary earlier precedent as having been overruled and sustained the penalty. Because the AR could not clarify whether the legal representatives inherited any estate or its extent, the Tribunal remanded the limited issue to the AO to determine the existence and extent of any estate capable of meeting the liability and to proceed accordingly.
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