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...
Reassessment beyond three years required the recorded reasons to show that the alleged escaped income was represented by an asset, expenditure, or entry in the books; absent that jurisdictional nexus, the notices and reassessment orders for AYs 2017-18 to 2019-20 were quashed. Material brought by a third person in response to summons during search could not be treated as search-seizure material to sustain notices under the search deeming fiction, so those notices were also invalid. The Tribunal further held that search information must relate to the relevant AY, and the absence of that link vitiated the notices for AYs 2020-21 to 2022-23. On merits, the wholesale two-zeroes theory on all cash entries was rejected, but 16% profit on recomputed unaccounted receipts was sustained.
Reassessment beyond three years required the recorded reasons to show that the alleged escaped income was represented by an asset, expenditure, or entry in the books; absent that jurisdictional nexus, the notices and reassessment orders for AYs 2017-18 to 2019-20 were quashed. Material brought by a third person in response to summons during search could not be treated as search-seizure material to sustain notices under the search deeming fiction, so those notices were also invalid. The Tribunal further held that search information must relate to the relevant AY, and the absence of that link vitiated the notices for AYs 2020-21 to 2022-23. On merits, the wholesale two-zeroes theory on all cash entries was rejected, but 16% profit on recomputed unaccounted receipts was sustained.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
