Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Notice issued to a deceased person is void ab initio, and all consequential reassessment proceedings fail for want of jurisdiction. The Court applied the principle that proceedings initiated after the assessee's death cannot be validated by the machinery for legal representatives; that mechanism operates only where proceedings were already commenced during the assessee's lifetime. Because the reassessment-related proceedings were admittedly initiated after death, the defect went to the root of the matter and the entire action was set aside.
Notice issued to a deceased person is void ab initio, and all consequential reassessment proceedings fail for want of jurisdiction. The Court applied the principle that proceedings initiated after the assessee's death cannot be validated by the machinery for legal representatives; that mechanism operates only where proceedings were already commenced during the assessee's lifetime. Because the reassessment-related proceedings were admittedly initiated after death, the defect went to the root of the matter and the entire action was set aside.
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