Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Reassessment proceedings initiated by a notice issued in the name of an assessee already deceased are jurisdictionally defective. A valid reassessment notice must be addressed to a living assessee or, where permitted, to the legal representative. Provisions allowing continuation of existing proceedings against legal representatives do not cure proceedings initiated only after the assessee's death. Where no fresh notice is issued to the legal representatives within the prescribed period, the reassessment lacks jurisdiction. The notice, consequential reassessment proceedings and assessment order are void in law and liable to be quashed.
Reassessment proceedings initiated by a notice issued in the name of an assessee already deceased are jurisdictionally defective. A valid reassessment notice must be addressed to a living assessee or, where permitted, to the legal representative. Provisions allowing continuation of existing proceedings against legal representatives do not cure proceedings initiated only after the assessee's death. Where no fresh notice is issued to the legal representatives within the prescribed period, the reassessment lacks jurisdiction. The notice, consequential reassessment proceedings and assessment order are void in law and liable to be quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
