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...
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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