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 initiated on a mistaken factual premise and without a live nexus to incriminating material was held unsustainable, as the record did not link the assessee to the seized third-party material and the jurisdictional approval objection was unrebutted. The Tribunal also found that approval under the reassessment provisions had not been shown to be validly obtained and that the sanction was mechanical, so the reassessment order was quashed. On the alleged on-money addition, unexplained reliance on un-confronted Excel entries and third-party statements could not displace the assessee's banking records and other documents, and the section 69 addition was deleted.
Reassessment initiated on a mistaken factual premise and without a live nexus to incriminating material was held unsustainable, as the record did not link the assessee to the seized third-party material and the jurisdictional approval objection was unrebutted. The Tribunal also found that approval under the reassessment provisions had not been shown to be validly obtained and that the sanction was mechanical, so the reassessment order was quashed. On the alleged on-money addition, unexplained reliance on un-confronted Excel entries and third-party statements could not displace the assessee's banking records and other documents, and the section 69 addition was deleted.
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