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...
Fair and effective opportunity of hearing in faceless reassessment requires communications to reach the assessee through its notified or registered contact details. The High Court noted that the assessee had provided an email address in its return and had another registered on the income-tax portal and MCA database, but subsequent notices were sent only to a resigned auditor's email address. As this prevented an adequate response with supporting material, the assessment order and demand notice were quashed and remanded for fresh proceedings, including a response opportunity, video-conference hearing and speaking order. The merits and validity of service under Rule 127 were left open.
Fair and effective opportunity of hearing in faceless reassessment requires communications to reach the assessee through its notified or registered contact details. The High Court noted that the assessee had provided an email address in its return and had another registered on the income-tax portal and MCA database, but subsequent notices were sent only to a resigned auditor's email address. As this prevented an adequate response with supporting material, the assessment order and demand notice were quashed and remanded for fresh proceedings, including a response opportunity, video-conference hearing and speaking order. The merits and validity of service under Rule 127 were left open.
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