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...
Reopening of assessment - reason to believe - The Court evaluates the concept of "true and full disclosure" as mandated by Section 147, considering relevant legal precedents. It emphasizes that the duty lies on the assessee to disclose fully and truly all material facts necessary for assessment. The Court finds that the petitioner's submission regarding loan transactions does not negate the necessity for disclosure of material facts, particularly regarding cash transactions. Thus, the Court upholds the respondent's contention regarding lack of full disclosure.
Reopening of assessment - reason to believe - The Court evaluates the concept of "true and full disclosure" as mandated by Section 147, considering relevant legal precedents. It emphasizes that the duty lies on the assessee to disclose fully and truly all material facts necessary for assessment. The Court finds that the petitioner's submission regarding loan transactions does not negate the necessity for disclosure of material facts, particularly regarding cash transactions. Thus, the Court upholds the respondent's contention regarding lack of full disclosure.
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