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 - validity of notice as issued by the ITO who is below the rank of ld. PCIT - The statute never permitted in section 263 for delegation of power to the authority below for issuance of notice for initiation of proceedings. - The delegation if possible if permitted by the law. DR was unable to place any judgment against the submission of assessee. Accordingly, the notice issued U/s 263 is invalid. - AT
Revision u/s 263 - validity of notice as issued by the ITO who is below the rank of ld. PCIT - The statute never permitted in section 263 for delegation of power to the authority below for issuance of notice for initiation of proceedings. - The delegation if possible if permitted by the law. DR was unable to place any judgment against the submission of assessee. Accordingly, the notice issued U/s 263 is invalid. - AT
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