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...
Doctrine of Merger of an order - CIT(A) observed that the appeal has been merged with order of Revision passed by the CIT u/s 264 - Prohibition u/s 264(4) - the appeal of the assessee was pending before the Ld. CIT(A) during the relevant time when the matter was decided by the Ld. CIT u/s 264 - Therefore, the Ld. CIT under section 264 has exceeded his jurisdiction by passing the order which is not sustainable in the eyes of law. - Matter restored before CIT(A) - AT
Doctrine of Merger of an order - CIT(A) observed that the appeal has been merged with order of Revision passed by the CIT u/s 264 - Prohibition u/s 264(4) - the appeal of the assessee was pending before the Ld. CIT(A) during the relevant time when the matter was decided by the Ld. CIT u/s 264 - Therefore, the Ld. CIT under section 264 has exceeded his jurisdiction by passing the order which is not sustainable in the eyes of law. - Matter restored before CIT(A) - AT
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