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...
Undisclosed mutual fund and insurance investments were not treated as wholly unexplained because the assessee had produced balance sheet, capital account, investment statements and supporting land and crop-sale records, although some material remained self-serving and inconsistent. The Tribunal applied the principle that the Act taxes income, not gross receipts, and therefore rejected assessment of the entire investment as deemed income under section 115BBE. It restricted the addition to 5% of the impugned investment figure and directed taxation under the normal provisions instead of deemed-income taxation.
Undisclosed mutual fund and insurance investments were not treated as wholly unexplained because the assessee had produced balance sheet, capital account, investment statements and supporting land and crop-sale records, although some material remained self-serving and inconsistent. The Tribunal applied the principle that the Act taxes income, not gross receipts, and therefore rejected assessment of the entire investment as deemed income under section 115BBE. It restricted the addition to 5% of the impugned investment figure and directed taxation under the normal provisions instead of deemed-income taxation.
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