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...
Rectification u/s 154 - Chargeability of interest u/s 234B and 234C - income returned u/s 115JB - The return was assessed under section 143(3) of the Act, and no interest was charged under sections 234B and 234C as per the prevailing law. - Subsequently, a search and seizure operation was conducted, leading to proceedings under section 153A. The CIT(A) deleted all additions made in the assessment order under section 153A. - However, while giving appeal effect to the CIT(A)'s order, the Assessing Officer introduced a new issue of charging interest under sections 234B and 234C, which was not part of the original assessment or appeal. - The ITAT held that the Assessing Officer exceeded his jurisdiction by introducing a new issue of charging interest under sections 234B and 234C during appeal effect.
Rectification u/s 154 - Chargeability of interest u/s 234B and 234C - income returned u/s 115JB - The return was assessed under section 143(3) of the Act, and no interest was charged under sections 234B and 234C as per the prevailing law. - Subsequently, a search and seizure operation was conducted, leading to proceedings under section 153A. The CIT(A) deleted all additions made in the assessment order under section 153A. - However, while giving appeal effect to the CIT(A)'s order, the Assessing Officer introduced a new issue of charging interest under sections 234B and 234C, which was not part of the original assessment or appeal. - The ITAT held that the Assessing Officer exceeded his jurisdiction by introducing a new issue of charging interest under sections 234B and 234C during appeal effect.
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