Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
The statutory right of appeal is order-specific: an assessee may challenge only the order that creates a grievance, and an intimation under section 143(1) and an assessment under section 143(3) operate independently. Where the later assessment merely accepts the income already determined under section 143(1) and makes no fresh addition or other adverse variation, no grievance arises from that assessment order and no appeal lies against it. The Tribunal rejected the doctrine of merger, holding that a challenge to adjustments made under section 143(1) must be taken against that order itself, not indirectly through an appeal against the later assessment. The dismissal of the appeal was therefore upheld.
The statutory right of appeal is order-specific: an assessee may challenge only the order that creates a grievance, and an intimation under section 143(1) and an assessment under section 143(3) operate independently. Where the later assessment merely accepts the income already determined under section 143(1) and makes no fresh addition or other adverse variation, no grievance arises from that assessment order and no appeal lies against it. The Tribunal rejected the doctrine of merger, holding that a challenge to adjustments made under section 143(1) must be taken against that order itself, not indirectly through an appeal against the later assessment. The dismissal of the appeal was therefore upheld.
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