Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
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Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
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Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Section 270AA gives finality where an assessee accepts the assessment without appeal and secures immunity from penalty and prosecution; a later section 154 rectification cannot be used to substantially rewrite the assessment or change its tax consequence, so the rectification order was without jurisdiction. An ad hoc disallowance of expenditure already recorded in the books and reflected in the accounts is not unexplained expenditure under section 69C; it is only an estimated disallowance for want of verification, so section 115BBE could not be applied in rectification proceedings. The Tribunal quashed both the rectification order and the appellate order affirming it.
Section 270AA gives finality where an assessee accepts the assessment without appeal and secures immunity from penalty and prosecution; a later section 154 rectification cannot be used to substantially rewrite the assessment or change its tax consequence, so the rectification order was without jurisdiction. An ad hoc disallowance of expenditure already recorded in the books and reflected in the accounts is not unexplained expenditure under section 69C; it is only an estimated disallowance for want of verification, so section 115BBE could not be applied in rectification proceedings. The Tribunal quashed both the rectification order and the appellate order affirming it.
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