Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
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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...
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Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Unexplained cash credit u/s 68 - share capital/share premium receipts - Despite substantial evidence provided by the appellant, including bank statements, share allotment documents, and resolutions of the board of directors, the AO failed to conduct further investigation, particularly after being informed of the change in the registered office address of the investing company. The Tribunal notes the reliance by the AO on the non-production of directors of the investing company for making the addition, without adequately considering the evidence provided by the appellant. - Additions directed to be deleted.
Unexplained cash credit u/s 68 - share capital/share premium receipts - Despite substantial evidence provided by the appellant, including bank statements, share allotment documents, and resolutions of the board of directors, the AO failed to conduct further investigation, particularly after being informed of the change in the registered office address of the investing company. The Tribunal notes the reliance by the AO on the non-production of directors of the investing company for making the addition, without adequately considering the evidence provided by the appellant. - Additions directed to be deleted.
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