Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
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Advance-tax payment otherwise payable is a precondition to admission of an income-tax appeal where no return of income has been filed, unless exemption is sought and granted for good and sufficient reason. A claimed absence of taxable income and corresponding advance-tax liability requires examination where neither the taxpayer nor the Assessing Officer has computed the liability; it cannot be rejected summarily merely because no exemption application was filed. Dismissal for non-compliance in those circumstances requires fresh consideration with an opportunity to explain the claim. Penalty appeals concerning under-reporting of income and audit default, where based on the same admission objection, follow the same treatment.
Advance-tax payment otherwise payable is a precondition to admission of an income-tax appeal where no return of income has been filed, unless exemption is sought and granted for good and sufficient reason. A claimed absence of taxable income and corresponding advance-tax liability requires examination where neither the taxpayer nor the Assessing Officer has computed the liability; it cannot be rejected summarily merely because no exemption application was filed. Dismissal for non-compliance in those circumstances requires fresh consideration with an opportunity to explain the claim. Penalty appeals concerning under-reporting of income and audit default, where based on the same admission objection, follow the same treatment.
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