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...
Seeking review of order - error apparent on the face of record or not - The court acknowledged the existence of the amendment to Paragraph 9.3 of the Handbook of Procedures and recognized its relevance to the case. However, it concluded that the amendment had been duly considered in the earlier order, and there was no error apparent on the face of the record regarding its application. In line with the respondents' argument, the court emphasized that a review cannot be used as a disguised appeal. It cited a Supreme Court decision that cautioned against exceeding jurisdiction in review applications and reiterated the principle that a review cannot reevaluate evidence already considered in the main petition.
Seeking review of order - error apparent on the face of record or not - The court acknowledged the existence of the amendment to Paragraph 9.3 of the Handbook of Procedures and recognized its relevance to the case. However, it concluded that the amendment had been duly considered in the earlier order, and there was no error apparent on the face of the record regarding its application. In line with the respondents' argument, the court emphasized that a review cannot be used as a disguised appeal. It cited a Supreme Court decision that cautioned against exceeding jurisdiction in review applications and reiterated the principle that a review cannot reevaluate evidence already considered in the main petition.
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