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...
Substantial Government financing under section 10(23C)(iiiab) is tested with reference to Government grants received during the relevant previous year, as prescribed by the Explanation and Rule 2BBB, and not by cumulative grants from earlier years. The provision requires those grants to exceed 50% of total receipts, including voluntary contributions, for that year. Because the assessee's Government grants fell below that threshold in each relevant year, the statutory condition for exemption was not met. The educational-purpose condition was not in dispute, but exemption was still denied and the denial was upheld.
Substantial Government financing under section 10(23C)(iiiab) is tested with reference to Government grants received during the relevant previous year, as prescribed by the Explanation and Rule 2BBB, and not by cumulative grants from earlier years. The provision requires those grants to exceed 50% of total receipts, including voluntary contributions, for that year. Because the assessee's Government grants fell below that threshold in each relevant year, the statutory condition for exemption was not met. The educational-purpose condition was not in dispute, but exemption was still denied and the denial was upheld.
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