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...
Bogus political donation claims under section 80GGC require the assessee to prove that the donation satisfies the statutory conditions for deduction; mere bank transfer, donation receipt, or the political party's registration is not enough. Where search material, statements, bank trail analysis and surrounding circumstances show the party acted as a conduit in an accommodation entry arrangement, authorities may apply human probabilities and the preponderance of probabilities to find the transaction -genuine, without direct proof of cash return being indispensable. Once such a cogent chain is established, the burden shifts to the assessee to rebut it with credible material. The deduction was disallowed and the appeal was dismissed.
Bogus political donation claims under section 80GGC require the assessee to prove that the donation satisfies the statutory conditions for deduction; mere bank transfer, donation receipt, or the political party's registration is not enough. Where search material, statements, bank trail analysis and surrounding circumstances show the party acted as a conduit in an accommodation entry arrangement, authorities may apply human probabilities and the preponderance of probabilities to find the transaction -genuine, without direct proof of cash return being indispensable. Once such a cogent chain is established, the burden shifts to the assessee to rebut it with credible material. The deduction was disallowed and the appeal was dismissed.
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