Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
A composite assessment order covering more than one tax period was held unsustainable where the court applied its earlier view that a single show-cause notice or assessment order cannot span multiple tax periods once annual return due dates have been reached. The impugned order, which covered several financial years, was set aside on that defect alone. The petitioner had confined the challenge to this point, so the other objections were left open. Fresh proceedings were permitted year-wise, with the intervening period excluded for limitation purposes.
A composite assessment order covering more than one tax period was held unsustainable where the court applied its earlier view that a single show-cause notice or assessment order cannot span multiple tax periods once annual return due dates have been reached. The impugned order, which covered several financial years, was set aside on that defect alone. The petitioner had confined the challenge to this point, so the other objections were left open. Fresh proceedings were permitted year-wise, with the intervening period excluded for limitation purposes.
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