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...
Characterization of income - subscriptions received from the public at large under a collective investment scheme - assessee shown these as income in P/L account - it is clear that on general principles also such subscription cannot possibly be treated as income and it would not be possible to go only by the treatment of such subscriptions in the hands of accounts of the assessee itself - receipts in question were capital receipts and not income.
Characterization of income - subscriptions received from the public at large under a collective investment scheme - assessee shown these as income in P/L account - it is clear that on general principles also such subscription cannot possibly be treated as income and it would not be possible to go only by the treatment of such subscriptions in the hands of accounts of the assessee itself - receipts in question were capital receipts and not income.
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