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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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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