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...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
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Reopening of assessment under section 147 was invalid where it was based on the same material already examined in the original scrutiny, with no new tangible information, and on an incorrect factual premise that separate research and development accounts were not maintained. The Tribunal treated this as a mere change of opinion after four years and held the jurisdictional assumption bad in law. On merits, it found no multiple deduction: the disputed depreciation was already included in research and development expenditure and had been added back in the income computation, so no further disallowance survived. The appellate authority also could not uphold denial of weighted deduction beyond the reassessment order without enhancement notice.
Reopening of assessment under section 147 was invalid where it was based on the same material already examined in the original scrutiny, with no new tangible information, and on an incorrect factual premise that separate research and development accounts were not maintained. The Tribunal treated this as a mere change of opinion after four years and held the jurisdictional assumption bad in law. On merits, it found no multiple deduction: the disputed depreciation was already included in research and development expenditure and had been added back in the income computation, so no further disallowance survived. The appellate authority also could not uphold denial of weighted deduction beyond the reassessment order without enhancement notice.
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