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...
A search assessment founded on a single consolidated satisfaction note covering multiple assessment years, without year-wise identification of material, was held to suffer from a fatal jurisdictional defect. The Tribunal held that the assessee could challenge the validity of the foundational assessment in appeal against the revision order, and that the original assessment was void in law because valid jurisdiction under the search assessment provisions had not been assumed for the year in question. As the foundational assessment was unsustainable, the revisionary order under section 263 could not survive and was set aside.
A search assessment founded on a single consolidated satisfaction note covering multiple assessment years, without year-wise identification of material, was held to suffer from a fatal jurisdictional defect. The Tribunal held that the assessee could challenge the validity of the foundational assessment in appeal against the revision order, and that the original assessment was void in law because valid jurisdiction under the search assessment provisions had not been assumed for the year in question. As the foundational assessment was unsustainable, the revisionary order under section 263 could not survive and was set aside.
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