Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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...
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Validity of reopening of assessment - An order u/s 245D(4) already been passed by the Income Tax Settlement Commission (ITSC) - Scope of harmonious construction - The Delhi High Court, in this judgment, reinforced the binding and conclusive nature of orders passed by the Income Tax Settlement Commission, underscoring that once an assessment year's matters have been settled by ITSC, they cannot be reopened by the Income Tax Department under Section 147/148, except under specific circumstances of fraud or misrepresentation. This decision highlights the judiciary's commitment to uphold the finality and sanctity of ITSC's settlements, aiming to prevent administrative uncertainty and protect the interests of assessees who opt for settlement proceedings.
Validity of reopening of assessment - An order u/s 245D(4) already been passed by the Income Tax Settlement Commission (ITSC) - Scope of harmonious construction - The Delhi High Court, in this judgment, reinforced the binding and conclusive nature of orders passed by the Income Tax Settlement Commission, underscoring that once an assessment year's matters have been settled by ITSC, they cannot be reopened by the Income Tax Department under Section 147/148, except under specific circumstances of fraud or misrepresentation. This decision highlights the judiciary's commitment to uphold the finality and sanctity of ITSC's settlements, aiming to prevent administrative uncertainty and protect the interests of assessees who opt for settlement proceedings.
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