Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The piece addresses the mandatory nature of a signature on reopening notices, explaining that the statutory use of "shall" requires signing even for electronic communications and that a deeming/authentication clause does not negate this obligation; consequently an unsigned notice is invalid and void ab initio. The legal effect is that an invalid notice cannot confer jurisdiction on the assessing officer to invoke reassessment under the reopening provisions, rendering any reassessment and downstream proceedings a nullity. The conclusion emphasises compliance with signature formalities as determinative of jurisdictional validity.
The piece addresses the mandatory nature of a signature on reopening notices, explaining that the statutory use of "shall" requires signing even for electronic communications and that a deeming/authentication clause does not negate this obligation; consequently an unsigned notice is invalid and void ab initio. The legal effect is that an invalid notice cannot confer jurisdiction on the assessing officer to invoke reassessment under the reopening provisions, rendering any reassessment and downstream proceedings a nullity. The conclusion emphasises compliance with signature formalities as determinative of jurisdictional validity.
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