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...
Interest under section 234B was held not leviable where the assessee computed and paid advance tax in accordance with the law then in force, and the shortfall arose only because ICDS applicability was later deferred by a retrospective legal change. The Tribunal held that default in advance tax must be tested on the basis of the law existing when the assessee was required to estimate current income and pay advance tax. Since the later change was not foreseeable at the relevant time, the assessee could not be treated as in default, and the interest demand was deleted.
Interest under section 234B was held not leviable where the assessee computed and paid advance tax in accordance with the law then in force, and the shortfall arose only because ICDS applicability was later deferred by a retrospective legal change. The Tribunal held that default in advance tax must be tested on the basis of the law existing when the assessee was required to estimate current income and pay advance tax. Since the later change was not foreseeable at the relevant time, the assessee could not be treated as in default, and the interest demand was deleted.
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