Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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...
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Completed liquidation and sale of a corporate debtor as a going concern can make income-tax appeals on pre-IBC additions infructuous where the liquidation has closed and subsisting NCLT directions require pre-transfer liabilities to be dealt with only within the IBC framework. Because assessments, notices and proceedings for the pre-transfer period were barred against the transferred entity and its successors, the Tribunal treated any merits adjudication as academic and disposed of the appeals without examining the additions. The note also clarifies that the outcome was confined to the corporate debtor and did not decide any independent action against former management or other persons.
Completed liquidation and sale of a corporate debtor as a going concern can make income-tax appeals on pre-IBC additions infructuous where the liquidation has closed and subsisting NCLT directions require pre-transfer liabilities to be dealt with only within the IBC framework. Because assessments, notices and proceedings for the pre-transfer period were barred against the transferred entity and its successors, the Tribunal treated any merits adjudication as academic and disposed of the appeals without examining the additions. The note also clarifies that the outcome was confined to the corporate debtor and did not decide any independent action against former management or other persons.
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