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...
Validity of reopening notice - Absence of the manual/digital signature of the A.O in the copy of the Reopening notice - Elaborating on the term "signed", it was observed that that same was to be construed as giving one's name to signify assent or adhesion to by signing one's name; to attest by signing or when a person is unable to write his name then affixation of "mark" by such person. - The Tribunal highlighted significant procedural lapses, notably the absence of the Assessing Officer's signature on the notice under section 148, leading to the quashing of the assessment order. The Tribunal's decision underscores the importance of adhering to procedural requirements, emphasizing that such lapses can invalidate otherwise substantive assessments.
Validity of reopening notice - Absence of the manual/digital signature of the A.O in the copy of the Reopening notice - Elaborating on the term "signed", it was observed that that same was to be construed as giving one's name to signify assent or adhesion to by signing one's name; to attest by signing or when a person is unable to write his name then affixation of "mark" by such person. - The Tribunal highlighted significant procedural lapses, notably the absence of the Assessing Officer's signature on the notice under section 148, leading to the quashing of the assessment order. The Tribunal's decision underscores the importance of adhering to procedural requirements, emphasizing that such lapses can invalidate otherwise substantive assessments.
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