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...
Directly relevant additional evidence supporting commission paid to daily deposit collection agents was admitted because the lower authorities had not examined it, and the commission disallowance was remanded for fresh consideration. Interest estimated on non-performing loans to members was deleted because income from credit facilities provided by a co-operative society to its members qualified for deduction under section 80P(2)(a)(i), rendering the addition revenue neutral. Interest estimated by applying a uniform rate across housing, mortgage, personal, deposit-backed and overdraft loans was also deleted because those loan categories carried differential rates and the resulting enhanced income would qualify for the same deduction. The appeal was partly allowed.
Directly relevant additional evidence supporting commission paid to daily deposit collection agents was admitted because the lower authorities had not examined it, and the commission disallowance was remanded for fresh consideration. Interest estimated on non-performing loans to members was deleted because income from credit facilities provided by a co-operative society to its members qualified for deduction under section 80P(2)(a)(i), rendering the addition revenue neutral. Interest estimated by applying a uniform rate across housing, mortgage, personal, deposit-backed and overdraft loans was also deleted because those loan categories carried differential rates and the resulting enhanced income would qualify for the same deduction. The appeal was partly allowed.
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