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...
Payments of accumulated charitable income to another registered institution were treated as taxable under the deeming rule because the source of funds was accumulation and the recipient held charitable registration; the nomenclature of the transfer as project expenditure or implementation charges did not matter. The rectification under mistake apparent from record was upheld because the relevant facts were already on the assessment record and no fresh inquiry was needed, so the issue was not a debatable one or a review. A challenge based on denial of a video conference hearing in faceless appellate proceedings also failed for want of shown prejudice. Consequential interest was held mandatory and subject only to recomputation.
Payments of accumulated charitable income to another registered institution were treated as taxable under the deeming rule because the source of funds was accumulation and the recipient held charitable registration; the nomenclature of the transfer as project expenditure or implementation charges did not matter. The rectification under mistake apparent from record was upheld because the relevant facts were already on the assessment record and no fresh inquiry was needed, so the issue was not a debatable one or a review. A challenge based on denial of a video conference hearing in faceless appellate proceedings also failed for want of shown prejudice. Consequential interest was held mandatory and subject only to recomputation.
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