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...
Rectification u/s 154 application rejected as being time barred - The Appellate Tribunal agreed with the assessee's contention that the rectification application was not time-barred. It held that the clock for the four-year limitation period starts only when the assessee is in receipt of the order to be rectified. Since there was no evidence that the intimation under Section 143(1) was served on the assessee, the limitation period did not begin, and the application was well within the stipulated time.
Rectification u/s 154 application rejected as being time barred - The Appellate Tribunal agreed with the assessee's contention that the rectification application was not time-barred. It held that the clock for the four-year limitation period starts only when the assessee is in receipt of the order to be rectified. Since there was no evidence that the intimation under Section 143(1) was served on the assessee, the limitation period did not begin, and the application was well within the stipulated time.
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