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...
Revision u/s 263 - lack of enquiry - Deemed dividend u/s 2(22)(e) - AO had not only made the enquiry or verification to ascertain the applicability of section 2(22)(e) to the loan amounts received by the assessee from the other group companies, but a conscious decision was also taken by him in view the legal position as propounded by the Jurisdictional HC - revision set aside
Revision u/s 263 - lack of enquiry - Deemed dividend u/s 2(22)(e) - AO had not only made the enquiry or verification to ascertain the applicability of section 2(22)(e) to the loan amounts received by the assessee from the other group companies, but a conscious decision was also taken by him in view the legal position as propounded by the Jurisdictional HC - revision set aside
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