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...
Reopening of assessment u/s 147 consequent to revision proceedings u/s 263 pending - notice u/s 148 issued during the pendency of the assessment proceedings following the directions given by the PCIT - The High Court held that such a notice could not be issued as long as assessment proceedings were ongoing, as income cannot be considered to have escaped assessment until these proceedings are completed. Additionally, the court found the sanction granted under Section 151 of the Act to be invalid based on a previous ruling. Consequently, the petition was disposed of in favor of the petitioner.
Reopening of assessment u/s 147 consequent to revision proceedings u/s 263 pending - notice u/s 148 issued during the pendency of the assessment proceedings following the directions given by the PCIT - The High Court held that such a notice could not be issued as long as assessment proceedings were ongoing, as income cannot be considered to have escaped assessment until these proceedings are completed. Additionally, the court found the sanction granted under Section 151 of the Act to be invalid based on a previous ruling. Consequently, the petition was disposed of in favor of the petitioner.
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