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...
Pecuniary jurisdiction over statutory notices under section 143(2) must comply with CBDT instructions allocating cases by returned-income limits. Where an Income-tax Officer issues the notice despite the returned income exceeding that officer's prescribed limit, the defect concerns pecuniary rather than territorial jurisdiction; the territorial-jurisdiction objection rule does not apply. CBDT instructions bind the Department, and issue of a jurisdictional notice by an officer without pecuniary authority is an illegality, not a procedural irregularity capable of validation under section 292BB. The notices and consequential assessment were therefore treated as void from inception and quashed; other grounds remained academic.
Pecuniary jurisdiction over statutory notices under section 143(2) must comply with CBDT instructions allocating cases by returned-income limits. Where an Income-tax Officer issues the notice despite the returned income exceeding that officer's prescribed limit, the defect concerns pecuniary rather than territorial jurisdiction; the territorial-jurisdiction objection rule does not apply. CBDT instructions bind the Department, and issue of a jurisdictional notice by an officer without pecuniary authority is an illegality, not a procedural irregularity capable of validation under section 292BB. The notices and consequential assessment were therefore treated as void from inception and quashed; other grounds remained academic.
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