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...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Proceedings under section 153C were held without jurisdiction for A.Y. 2014-15 because the satisfaction note dated 31.05.2023 fixed A.Y. 2024-25 as the reckoning year, so the ten-year block could reach back only to A.Y. 2015-16 and not earlier; the notice and assessment for A.Y. 2014-15 were quashed. For A.Ys. 2015-16 and 2016-17, the Tribunal held that satisfaction recorded after 01.04.2021 could not sustain section 153C action against the other person, and proceedings ought to have been initiated under section 148 instead; the section 153C proceedings were quashed and the remaining grounds were left academic.
Proceedings under section 153C were held without jurisdiction for A.Y. 2014-15 because the satisfaction note dated 31.05.2023 fixed A.Y. 2024-25 as the reckoning year, so the ten-year block could reach back only to A.Y. 2015-16 and not earlier; the notice and assessment for A.Y. 2014-15 were quashed. For A.Ys. 2015-16 and 2016-17, the Tribunal held that satisfaction recorded after 01.04.2021 could not sustain section 153C action against the other person, and proceedings ought to have been initiated under section 148 instead; the section 153C proceedings were quashed and the remaining grounds were left academic.
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