Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
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...
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Assessment proceedings conducted in the name of a deceased taxpayer where no verifiable intimation of death or PAN surrender was placed on record do not render the assessment void ab initio; the defect is an irregularity curable by bringing the legal heirs on record and rectification under succession provisions (section 159) is appropriate. The administrative officers lack of knowledge of death is excused where legal heirs failed to promptly notify authorities, and precedent treating assessments on deceased persons as irregular rather than illegal supports rectification to bind legal heirs on record.
Assessment proceedings conducted in the name of a deceased taxpayer where no verifiable intimation of death or PAN surrender was placed on record do not render the assessment void ab initio; the defect is an irregularity curable by bringing the legal heirs on record and rectification under succession provisions (section 159) is appropriate. The administrative officers lack of knowledge of death is excused where legal heirs failed to promptly notify authorities, and precedent treating assessments on deceased persons as irregular rather than illegal supports rectification to bind legal heirs on record.
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