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...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Reassessment initiated beyond four years requires failure by the assessee to disclose fully and truly all material facts relating to the recorded escapement of income. Explanation 3 to section 147 permits assessment of other escaped income discovered during valid reassessment proceedings, but does not expand the jurisdictional basis for reopening or sustain proceedings when no addition is made on either recorded ground. Where the recorded reasons yield no addition and the requisite failure of disclosure is not established, the reopening lacks jurisdiction. The reassessment was quashed, and the Revenue's appeal was dismissed.
Reassessment initiated beyond four years requires failure by the assessee to disclose fully and truly all material facts relating to the recorded escapement of income. Explanation 3 to section 147 permits assessment of other escaped income discovered during valid reassessment proceedings, but does not expand the jurisdictional basis for reopening or sustain proceedings when no addition is made on either recorded ground. Where the recorded reasons yield no addition and the requisite failure of disclosure is not established, the reopening lacks jurisdiction. The reassessment was quashed, and the Revenue's appeal was dismissed.
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