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...
In closely held companies, share capital credits require proof of identity, creditworthiness and genuineness; mere documentary filing is not enough where enquiries create doubts, and the share capital and premium addition was restored. Alleged commission on accommodation entries could not be sustained on surmise alone, so relief was granted on that item. Sundry creditor transactions required fresh verification because unresolved mismatches and bona fides concerns remained, so the issue was remanded for enquiry. On gross profit, complete deletion was rejected, but the best-judgment estimate was moderated and the rate was directed to be recomputed at 7%.
In closely held companies, share capital credits require proof of identity, creditworthiness and genuineness; mere documentary filing is not enough where enquiries create doubts, and the share capital and premium addition was restored. Alleged commission on accommodation entries could not be sustained on surmise alone, so relief was granted on that item. Sundry creditor transactions required fresh verification because unresolved mismatches and bona fides concerns remained, so the issue was remanded for enquiry. On gross profit, complete deletion was rejected, but the best-judgment estimate was moderated and the rate was directed to be recomputed at 7%.
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