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...
Section 73(2) must be read with the adjudication limitation in Section 73(10): it requires issuance of notice at least three months before expiry of the order-making limitation, but does not mandate a three-month interval between notice and adjudication. Reasonable opportunity to respond remains necessary under natural justice. The discussion also identifies that assessment orders for the same period cannot rest on contradictory assumptions that supplies are both exempt for input tax credit purposes and taxable otherwise. Subject to stipulated remittance after adjustment of recoveries, the inconsistent orders were set aside and remanded for fresh consideration, including examination of whether the supplies are exempt.
Section 73(2) must be read with the adjudication limitation in Section 73(10): it requires issuance of notice at least three months before expiry of the order-making limitation, but does not mandate a three-month interval between notice and adjudication. Reasonable opportunity to respond remains necessary under natural justice. The discussion also identifies that assessment orders for the same period cannot rest on contradictory assumptions that supplies are both exempt for input tax credit purposes and taxable otherwise. Subject to stipulated remittance after adjustment of recoveries, the inconsistent orders were set aside and remanded for fresh consideration, including examination of whether the supplies are exempt.
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