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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A vested right of appeal attaches when original adjudicatory proceedings commence, including the conditions for access to the appellate forum. The notes explain that a subsequently introduced, onerous pre-deposit requirement cannot apply to pending proceedings unless the amendment expressly or necessarily provides for retrospective operation. Where a show-cause notice imposing personal penalty liability preceded substitution of the proviso to section 107(6), the earlier appellate regime governs. The substituted requirement to deposit ten per cent of disputed penalties therefore does not apply to penalty-only appeals arising from that notice, although any admitted amount remains payable. The Appellate Authority has no inherent power to waive an otherwise applicable statutory pre-deposit.
A vested right of appeal attaches when original adjudicatory proceedings commence, including the conditions for access to the appellate forum. The notes explain that a subsequently introduced, onerous pre-deposit requirement cannot apply to pending proceedings unless the amendment expressly or necessarily provides for retrospective operation. Where a show-cause notice imposing personal penalty liability preceded substitution of the proviso to section 107(6), the earlier appellate regime governs. The substituted requirement to deposit ten per cent of disputed penalties therefore does not apply to penalty-only appeals arising from that notice, although any admitted amount remains payable. The Appellate Authority has no inherent power to waive an otherwise applicable statutory pre-deposit.
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