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...
Jurisdictional objections in reassessment, including a notice issued in the name of a deceased assessee and alleged procedural non-compliance, must be addressed before merits where they could invalidate the reassessment. Section 250(6) requires the appellate authority to identify each point for determination, record its decision and provide reasons; a general reference to the assessment order does not constitute ground-wise reasoned adjudication. The authority's power to set aside a best-judgment assessment does not remove this obligation. Jurisdictional and legal grounds should be decided through a speaking order before additions are examined on merits, which arise only if the reassessment is valid.
Jurisdictional objections in reassessment, including a notice issued in the name of a deceased assessee and alleged procedural non-compliance, must be addressed before merits where they could invalidate the reassessment. Section 250(6) requires the appellate authority to identify each point for determination, record its decision and provide reasons; a general reference to the assessment order does not constitute ground-wise reasoned adjudication. The authority's power to set aside a best-judgment assessment does not remove this obligation. Jurisdictional and legal grounds should be decided through a speaking order before additions are examined on merits, which arise only if the reassessment is valid.
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