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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A repeated Section 94 application by a personal guarantor was held not maintainable after an earlier fresh petition had already been dismissed on merits as time-barred. The tribunal treated the later filing as an identical attempt, noting suppression of the intervening dismissal and a pattern of repeated petitions aimed at securing interim moratorium and delaying recovery. It also rejected the argument that limitation began only from the possession notice, because a separate demand notice had already been issued to the guarantor earlier; the limitation finding based on that earlier notice was upheld. On these facts, the subsequent petition was held barred by res judicata, the abuse of process was found serious, and costs were imposed.
A repeated Section 94 application by a personal guarantor was held not maintainable after an earlier fresh petition had already been dismissed on merits as time-barred. The tribunal treated the later filing as an identical attempt, noting suppression of the intervening dismissal and a pattern of repeated petitions aimed at securing interim moratorium and delaying recovery. It also rejected the argument that limitation began only from the possession notice, because a separate demand notice had already been issued to the guarantor earlier; the limitation finding based on that earlier notice was upheld. On these facts, the subsequent petition was held barred by res judicata, the abuse of process was found serious, and costs were imposed.
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