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...
Settlement application u/s 245C - Apportioning the undisclosed income in the hands of the petitioner and the Company - The High court examines the petitioner's disclosure and the basis for apportionment of income. It notes discrepancies and lack of clarity in the petitioner's submissions regarding the apportionment of unaccounted sales, expenditures, and income between the petitioner and the company. - The High court concurs with the Commission's finding that the petitioner did not disclose true and correct facts, violating the requirements of Section 245C(1).
Settlement application u/s 245C - Apportioning the undisclosed income in the hands of the petitioner and the Company - The High court examines the petitioner's disclosure and the basis for apportionment of income. It notes discrepancies and lack of clarity in the petitioner's submissions regarding the apportionment of unaccounted sales, expenditures, and income between the petitioner and the company. - The High court concurs with the Commission's finding that the petitioner did not disclose true and correct facts, violating the requirements of Section 245C(1).
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