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...
Validity of reopening of assessment u/s 147 - notice issued to a company which is non-existent on the date as it stood amalgamated with the appellant/petitioner - ts conduct of filing return of income in the name of OAS after the amalgamation and obtained refunds issued in the name of OAS, which will all go to show that M/s.OAS continued to exist even after amalgamation. - Therefore, appellant cannot canvass the point that OAS was nonexistent and the proceedings initiated in its name would be bad in law. - HC
Validity of reopening of assessment u/s 147 - notice issued to a company which is non-existent on the date as it stood amalgamated with the appellant/petitioner - ts conduct of filing return of income in the name of OAS after the amalgamation and obtained refunds issued in the name of OAS, which will all go to show that M/s.OAS continued to exist even after amalgamation. - Therefore, appellant cannot canvass the point that OAS was nonexistent and the proceedings initiated in its name would be bad in law. - HC
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