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...
Reassessment proceeding under Section 147 was made to form change of opinion and therefore, it would clearly amount to reviewing the original order of assessment u/s 147 under the pretext of reassessment. We make it clear that in the reassessment proceedings u/s 147, the original assessment order cannot be reviewed. Proceedings also cannot be initiated merely because there is a possibility of change of opinion. - HC
Reassessment proceeding under Section 147 was made to form change of opinion and therefore, it would clearly amount to reviewing the original order of assessment u/s 147 under the pretext of reassessment. We make it clear that in the reassessment proceedings u/s 147, the original assessment order cannot be reviewed. Proceedings also cannot be initiated merely because there is a possibility of change of opinion. - HC
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