Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
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...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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The HC held that under s.159(1)-(2)(b) the legal representative is liable for tax liabilities of the deceased and proceedings capable of being taken against the deceased may be continued against the legal representative. The court found no merit in challenges to jurisdiction or limitation of notices issued post-death, observing the petitioner failed to notify the Department of the death; assessments properly remained in the name of the deceased with liability to be fastened on legal representatives. The HC rejected jurisdictional/limitation pleas to the extent raised, quashed the impugned orders, and remitted the matter to the 1st respondent for a fresh merits adjudication; the remand bars relitigation of limitation or jurisdiction.
The HC held that under s.159(1)-(2)(b) the legal representative is liable for tax liabilities of the deceased and proceedings capable of being taken against the deceased may be continued against the legal representative. The court found no merit in challenges to jurisdiction or limitation of notices issued post-death, observing the petitioner failed to notify the Department of the death; assessments properly remained in the name of the deceased with liability to be fastened on legal representatives. The HC rejected jurisdictional/limitation pleas to the extent raised, quashed the impugned orders, and remitted the matter to the 1st respondent for a fresh merits adjudication; the remand bars relitigation of limitation or jurisdiction.
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