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...
Delay in filing an appeal before CIT(A) - assessee was pursuing the matter at wrong forum - It can be appreciated that the Assessee’s claim is primarily is of wrong advice in choosing the forum under law to contest the assessment order - The stringent laws of limitation require liberal interpretation. In the case in hand apparently the ld CIT(A) has not gone at all into discussing the grounds which were submitted and with the cursory observations the appeal has been dismissed barred by limitation - Delay condoned - AT
Delay in filing an appeal before CIT(A) - assessee was pursuing the matter at wrong forum - It can be appreciated that the Assessee’s claim is primarily is of wrong advice in choosing the forum under law to contest the assessment order - The stringent laws of limitation require liberal interpretation. In the case in hand apparently the ld CIT(A) has not gone at all into discussing the grounds which were submitted and with the cursory observations the appeal has been dismissed barred by limitation - Delay condoned - AT
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