Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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...
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Revision u/s 263 by CIT - when the assessee's case was that the CIT had ignored the explanation and submission therefore, if the tribunal was of the view that the CIT did not consider the explanation, it would have been well justified to accept the explanation, submission and record a finding. The other option open would have been to send the mater back to CIT for re- examination of the explanation and submission of the assessee. Either of the two options had not been chosen by the tribunal but merely concluded by stating that the explanation offered by the assessee is acceptable without assigning any reasons therefore. - matter is remanded to the CIT for fresh consideration. - HC
Revision u/s 263 by CIT - when the assessee's case was that the CIT had ignored the explanation and submission therefore, if the tribunal was of the view that the CIT did not consider the explanation, it would have been well justified to accept the explanation, submission and record a finding. The other option open would have been to send the mater back to CIT for re- examination of the explanation and submission of the assessee. Either of the two options had not been chosen by the tribunal but merely concluded by stating that the explanation offered by the assessee is acceptable without assigning any reasons therefore. - matter is remanded to the CIT for fresh consideration. - HC
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