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...
Reassessment following a completed scrutiny assessment was initiated on alleged inflation of Special Economic Zone export profits through non-payment of interest on partners' capital and below-market gold purchases from a sister concern. Relevant transaction particulars had been available during the original assessment, while the amended partnership deed-specifically brought to the Assessing Officer's attention-had rendered the interest-payment clause inoperative. The reopening nevertheless relied on the original deed. Objections concerning the rate and fineness of gold were also not addressed. The reassessment notice and the order rejecting objections were quashed, and the writ petition succeeded.
Reassessment following a completed scrutiny assessment was initiated on alleged inflation of Special Economic Zone export profits through non-payment of interest on partners' capital and below-market gold purchases from a sister concern. Relevant transaction particulars had been available during the original assessment, while the amended partnership deed-specifically brought to the Assessing Officer's attention-had rendered the interest-payment clause inoperative. The reopening nevertheless relied on the original deed. Objections concerning the rate and fineness of gold were also not addressed. The reassessment notice and the order rejecting objections were quashed, and the writ petition succeeded.
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