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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Reassessment for a claimed deduction for political contributions under section 80GGC may examine whether the payment was a genuine donation or an accommodation entry. The Tribunal's reported analysis states that banking-channel payments and donation receipts do not prevent scrutiny of surrounding circumstances. Investigation material, statements recorded under section 132(4), bank-trail analysis and evidence of fund layering by the recipient political party were treated as a chain of circumstances under the test of human probabilities, indicating an accommodation entry. The article reports that the reassessment notice was validly issued, the deduction was disallowed, and the appeal was dismissed.
Reassessment for a claimed deduction for political contributions under section 80GGC may examine whether the payment was a genuine donation or an accommodation entry. The Tribunal's reported analysis states that banking-channel payments and donation receipts do not prevent scrutiny of surrounding circumstances. Investigation material, statements recorded under section 132(4), bank-trail analysis and evidence of fund layering by the recipient political party were treated as a chain of circumstances under the test of human probabilities, indicating an accommodation entry. The article reports that the reassessment notice was validly issued, the deduction was disallowed, and the appeal was dismissed.
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