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...
Validity of Reopening of assessment - period of limitation - Although the notice dated 30.06.2021 u/s 148 bears an endorsement at the foot of the page that it has been digitally signed, it is inchoate, in the sense that it is not accompanied by a date. - Admittedly, the said notice was never physically delivered to the assessee. As such, the fact remains that service of the said notice u/s 148 was affected on the petitioner only on 16.07.2021 through email, though the limitation period had already expired on 30.06.2021. - HC
Validity of Reopening of assessment - period of limitation - Although the notice dated 30.06.2021 u/s 148 bears an endorsement at the foot of the page that it has been digitally signed, it is inchoate, in the sense that it is not accompanied by a date. - Admittedly, the said notice was never physically delivered to the assessee. As such, the fact remains that service of the said notice u/s 148 was affected on the petitioner only on 16.07.2021 through email, though the limitation period had already expired on 30.06.2021. - HC
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