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 u/s 147 - Reasons to believe - The High Court examined the submissions and found that the notice for reopening the assessment lacked jurisdiction. It noted that the reasons for reopening were not based on any fresh material but were already considered during the regular assessment process. Additionally, the Court highlighted that reopening the assessment solely on the basis of audit party objections was invalid. Moreover, the Court agreed with the petitioner's argument regarding the applicability of MAT provisions, stating that even if there were additions to income under normal provisions, it would not impact the MAT computation significantly. Therefore, the Court concluded that there was no escapement of income under normal provisions.
Reopening of assessment u/s 147 - Reasons to believe - The High Court examined the submissions and found that the notice for reopening the assessment lacked jurisdiction. It noted that the reasons for reopening were not based on any fresh material but were already considered during the regular assessment process. Additionally, the Court highlighted that reopening the assessment solely on the basis of audit party objections was invalid. Moreover, the Court agreed with the petitioner's argument regarding the applicability of MAT provisions, stating that even if there were additions to income under normal provisions, it would not impact the MAT computation significantly. Therefore, the Court concluded that there was no escapement of income under normal provisions.
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