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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An AO must pass the final assessment order in conformity with the DRP's directions under section 144C(13); any departure, even if said to be due to mistake or misunderstanding, is impermissible. Applying binding High Court precedent, the Tribunal quashed the non-compliant final assessment order because the AO repeated the draft order and ignored the relief granted by the DRP. The transfer pricing and consequential grounds were left open as academic.
An AO must pass the final assessment order in conformity with the DRP's directions under section 144C(13); any departure, even if said to be due to mistake or misunderstanding, is impermissible. Applying binding High Court precedent, the Tribunal quashed the non-compliant final assessment order because the AO repeated the draft order and ignored the relief granted by the DRP. The transfer pricing and consequential grounds were left open as academic.
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