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...
A bona fide deduction claim under section 80P(2)(a)(i), previously accepted in scrutiny assessment and rectification proceedings, was not treated as under-reported income in the stated circumstances. The notes state that section 270A(1) uses "may", requiring consideration of the full circumstances rather than automatic penalty. They further state that a penalty notice and order referring only generally to section 270A, without specifying the applicable sub-clause or limb, cannot sustain the penalty. The reported conclusion is that the penalty for under-reporting was deleted.
A bona fide deduction claim under section 80P(2)(a)(i), previously accepted in scrutiny assessment and rectification proceedings, was not treated as under-reported income in the stated circumstances. The notes state that section 270A(1) uses "may", requiring consideration of the full circumstances rather than automatic penalty. They further state that a penalty notice and order referring only generally to section 270A, without specifying the applicable sub-clause or limb, cannot sustain the penalty. The reported conclusion is that the penalty for under-reporting was deleted.
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