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...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Reassessment u/s 147 - In ‘Note’ in Annual Reports on Software development projects and the various stages of software development placed by the assessee before the AO discloses all information on project - it is presumed that AO has examined the entitlement of deduction u/s 10A in all angles and withdrawal of the same based on the assessment order for AY 2007-08 is without application of mind and nothing but change of opinion, which tantamounts to review and is not permissible
Reassessment u/s 147 - In ‘Note’ in Annual Reports on Software development projects and the various stages of software development placed by the assessee before the AO discloses all information on project - it is presumed that AO has examined the entitlement of deduction u/s 10A in all angles and withdrawal of the same based on the assessment order for AY 2007-08 is without application of mind and nothing but change of opinion, which tantamounts to review and is not permissible
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