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...
Audit Objections – relevance in making re-assessments - The function of the audit is essentially executive in nature, while the function of the assessing officer and his power to make an assessment are essentially quasi judicial in nature. One may also have to bear in mind that the executive cannot trench upon the powers of a quasi judicial authority for permitting to do so may result in subverting the scheme of quasi-judicial function of making assessment / reassessment, which is impermissible. - HC
Audit Objections – relevance in making re-assessments - The function of the audit is essentially executive in nature, while the function of the assessing officer and his power to make an assessment are essentially quasi judicial in nature. One may also have to bear in mind that the executive cannot trench upon the powers of a quasi judicial authority for permitting to do so may result in subverting the scheme of quasi-judicial function of making assessment / reassessment, which is impermissible. - HC
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