Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Section 282A(1) requires that every notice or document issued by an income tax authority be signed, whether in paper form or electronically; the deeming/authentication provision in subsection (2) does not supplant the mandatory signing requirement in subsection (1). An unsigned approval or notice therefore breaches the statutory mandate, is arbitrary and void ab initio, and cannot vest the Assessing Officer with jurisdiction to proceed under reassessment provisions. Consequent reassessment steps are non est, and the reassessment proceedings must be quashed.
Section 282A(1) requires that every notice or document issued by an income tax authority be signed, whether in paper form or electronically; the deeming/authentication provision in subsection (2) does not supplant the mandatory signing requirement in subsection (1). An unsigned approval or notice therefore breaches the statutory mandate, is arbitrary and void ab initio, and cannot vest the Assessing Officer with jurisdiction to proceed under reassessment provisions. Consequent reassessment steps are non est, and the reassessment proceedings must be quashed.
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