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...
Assessment u/s 153C - The High court found procedural lapses in invoking Section 153C against the petitioner without concrete evidence of undisclosed transactions for the relevant assessment year. It highlighted the absence of incriminating material specific to the petitioner for the year in question, rendering the invocation of Section 153C unjustifiable. - Reassessment under Section 148: The court clarified that proceedings under Section 148, aimed at reassessing income believed to have escaped assessment, could continue provided they were based on substantive evidence and not merely on the procedural fallout of a search operation targeting a different entity.
Assessment u/s 153C - The High court found procedural lapses in invoking Section 153C against the petitioner without concrete evidence of undisclosed transactions for the relevant assessment year. It highlighted the absence of incriminating material specific to the petitioner for the year in question, rendering the invocation of Section 153C unjustifiable. - Reassessment under Section 148: The court clarified that proceedings under Section 148, aimed at reassessing income believed to have escaped assessment, could continue provided they were based on substantive evidence and not merely on the procedural fallout of a search operation targeting a different entity.
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