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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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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...
Reassessment was initiated by issuing a notice under section 148 in the name of a deceased assessee and, despite being informed of the death, the tax authorities continued the reassessment without substituting or issuing notice to the legal representatives as required by law. Since reassessment proceedings cannot validly proceed against a dead person, both the reopening notice and the consequential reassessment order were set aside. The authorities were permitted to reinitiate reassessment in accordance with law by issuing a fresh section 148 notice after complying with statutory formalities to the legal representatives, who were directed to disclose details of other legal representatives upon requisition. - HC
Reassessment was initiated by issuing a notice under section 148 in the name of a deceased assessee and, despite being informed of the death, the tax authorities continued the reassessment without substituting or issuing notice to the legal representatives as required by law. Since reassessment proceedings cannot validly proceed against a dead person, both the reopening notice and the consequential reassessment order were set aside. The authorities were permitted to reinitiate reassessment in accordance with law by issuing a fresh section 148 notice after complying with statutory formalities to the legal representatives, who were directed to disclose details of other legal representatives upon requisition. - HC
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