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...
Reopening of assessment u/s 147 - Plainly, in the facts as noted above, no sanction was required to be obtained at the stage of initiation of reassessment proceedings. Therefore, initiation of reassessment proceeding was well founded on satisfaction as to escapement of income, from tax. The fact that some part of the allegation of escapement is being dropped or not pursued at the stage of quantification of income, may not nullify the assumption of jurisdiction, by now invoking section 149. - HC
Reopening of assessment u/s 147 - Plainly, in the facts as noted above, no sanction was required to be obtained at the stage of initiation of reassessment proceedings. Therefore, initiation of reassessment proceeding was well founded on satisfaction as to escapement of income, from tax. The fact that some part of the allegation of escapement is being dropped or not pursued at the stage of quantification of income, may not nullify the assumption of jurisdiction, by now invoking section 149. - HC
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