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...
Extended period of limitation - The assessee has not disclosed the value of taxable service for the period 10.9.2004 to 31.7.2007 in their ST 3 Returns filed to the department. Only when the department issued a show cause notice, the responded bank remitted the amount of tax. Hence, merely because they were exonerated under Section 80 of the Act from payment of penalty for reasonable cause for non payment the same yardstick cannot be taken by the bank to contend that the extended period of limitation as prescribed under proviso to section 73 of the Act is available. - HC
Extended period of limitation - The assessee has not disclosed the value of taxable service for the period 10.9.2004 to 31.7.2007 in their ST 3 Returns filed to the department. Only when the department issued a show cause notice, the responded bank remitted the amount of tax. Hence, merely because they were exonerated under Section 80 of the Act from payment of penalty for reasonable cause for non payment the same yardstick cannot be taken by the bank to contend that the extended period of limitation as prescribed under proviso to section 73 of the Act is available. - HC
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