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...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Allowability of Derivative loss - separate addition on account of alleged payment of margin monies on an estimated basis - The Tribunal emphasized that in derivative transactions, the actual transfer of money under the heads 'purchase and sale' is notional, and only the resultant difference paid or received at the end of the transaction is relevant. The Tribunal recognized that losses incurred in derivative transactions, if paid by the assessee through regular banking channels and adequately evidenced, should not lead to additional disallowance on an estimated basis for alleged payment of margin monies. - AT
Allowability of Derivative loss - separate addition on account of alleged payment of margin monies on an estimated basis - The Tribunal emphasized that in derivative transactions, the actual transfer of money under the heads 'purchase and sale' is notional, and only the resultant difference paid or received at the end of the transaction is relevant. The Tribunal recognized that losses incurred in derivative transactions, if paid by the assessee through regular banking channels and adequately evidenced, should not lead to additional disallowance on an estimated basis for alleged payment of margin monies. - AT
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