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...
The Tribunal held that the extended reassessment period beyond three years was unavailable because the alleged escaped income related only to a claimed donation deduction and did not meet the statutory monetary threshold for extension. It further found that, even after excluding the time allowed to respond to the section 148A(b) notice, the Assessing Officer had time only until 07/04/2023 to issue the reassessment notice, but it was issued on 10/04/2023. The sixth proviso was therefore inapplicable, and the reassessment notice was time-barred and invalid; the merits of the disallowance were left open.
The Tribunal held that the extended reassessment period beyond three years was unavailable because the alleged escaped income related only to a claimed donation deduction and did not meet the statutory monetary threshold for extension. It further found that, even after excluding the time allowed to respond to the section 148A(b) notice, the Assessing Officer had time only until 07/04/2023 to issue the reassessment notice, but it was issued on 10/04/2023. The sixth proviso was therefore inapplicable, and the reassessment notice was time-barred and invalid; the merits of the disallowance were left open.
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