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...
Material seized from a company director who managed its day-to-day affairs and was searched simultaneously could be used for the company's assessment under section 153A; separate proceedings under section 153C were unnecessary. The Tribunal found the consolidated section 153D approval for four assessment years mechanical because it showed no year-wise application of mind, quashing the assessments. For unabated years, the consistently accepted Project Completion Method could not be replaced by the Percentage Completion Method without relevant seized material, rejection of accounts under section 145(3), or a cogent factual basis; the resulting additions were deleted. Additions for both receipts and payments reflected in the same seized papers were also deleted as double taxation of income already offered and accepted.
Material seized from a company director who managed its day-to-day affairs and was searched simultaneously could be used for the company's assessment under section 153A; separate proceedings under section 153C were unnecessary. The Tribunal found the consolidated section 153D approval for four assessment years mechanical because it showed no year-wise application of mind, quashing the assessments. For unabated years, the consistently accepted Project Completion Method could not be replaced by the Percentage Completion Method without relevant seized material, rejection of accounts under section 145(3), or a cogent factual basis; the resulting additions were deleted. Additions for both receipts and payments reflected in the same seized papers were also deleted as double taxation of income already offered and accepted.
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