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...
A pure legal challenge to a reassessment notice was admitted in cross objection because it went to the root of jurisdiction and had already been raised below. On merits, the ITAT held that a reopening notice issued beyond six years from the end of the relevant assessment year was time-barred. Applying the jurisdictional High Court view, it ruled that the extended reassessment limitation under the amended law operates prospectively and does not revive cases where the old six-year period had already expired. The notice was quashed, the reassessment was invalidated, the assessee's cross objection was allowed, and the Revenue's appeal on merits failed.
A pure legal challenge to a reassessment notice was admitted in cross objection because it went to the root of jurisdiction and had already been raised below. On merits, the ITAT held that a reopening notice issued beyond six years from the end of the relevant assessment year was time-barred. Applying the jurisdictional High Court view, it ruled that the extended reassessment limitation under the amended law operates prospectively and does not revive cases where the old six-year period had already expired. The notice was quashed, the reassessment was invalidated, the assessee's cross objection was allowed, and the Revenue's appeal on merits failed.
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