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...
Assessment under the Black Money Act starts only on service of notice under section 10, so no assessment proceedings exist in law before that date. On that basis, time excluded for foreign information exchange under Explanation 1 to section 11 can cover only the period overlapping with the running assessment period, not any earlier period before notice service. The Tribunal held that the Revenue wrongly excluded pre-notice time, and the assessment was completed after the last permissible date. The order was therefore time-barred, without jurisdiction and non est, and was quashed; the merits were left open and the departmental appeal became infructuous.
Assessment under the Black Money Act starts only on service of notice under section 10, so no assessment proceedings exist in law before that date. On that basis, time excluded for foreign information exchange under Explanation 1 to section 11 can cover only the period overlapping with the running assessment period, not any earlier period before notice service. The Tribunal held that the Revenue wrongly excluded pre-notice time, and the assessment was completed after the last permissible date. The order was therefore time-barred, without jurisdiction and non est, and was quashed; the merits were left open and the departmental appeal became infructuous.
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