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...
Penalty u/s 271(1)(b) - non compliance to statutory notice u/s 143(2) - there was irregularity in disposing of the objection raised by the assessee against re-opening u/s 147 r.w.s. 148 of the Act which was after four months. Therefore there is irregularity on the part of AO also, which we have observed with the help of sequence of events narrated above, therefore, we note that there is sufficient compliance on the part of assessee to response such notices. - No penalty - AT
Penalty u/s 271(1)(b) - non compliance to statutory notice u/s 143(2) - there was irregularity in disposing of the objection raised by the assessee against re-opening u/s 147 r.w.s. 148 of the Act which was after four months. Therefore there is irregularity on the part of AO also, which we have observed with the help of sequence of events narrated above, therefore, we note that there is sufficient compliance on the part of assessee to response such notices. - No penalty - AT
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