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 against a dissolved partnership firm after its business succession is void where the Department had accepted that the firm ceased to exist and the successor proprietor disclosed and was assessed on the same business transactions and bank accounts. Assessing the erstwhile firm in these circumstances would duplicate taxation of the same business income. Jurisdiction for reassessment also requires recorded reasons identifying the relevant bank account or transaction and foundational material showing income escaped assessment; vague reasons do not meet that standard. A notice issued to a non-existent entity after succession renders the consequential assessment and estimated addition unsustainable.
Reassessment against a dissolved partnership firm after its business succession is void where the Department had accepted that the firm ceased to exist and the successor proprietor disclosed and was assessed on the same business transactions and bank accounts. Assessing the erstwhile firm in these circumstances would duplicate taxation of the same business income. Jurisdiction for reassessment also requires recorded reasons identifying the relevant bank account or transaction and foundational material showing income escaped assessment; vague reasons do not meet that standard. A notice issued to a non-existent entity after succession renders the consequential assessment and estimated addition unsustainable.
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