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...
Validity of reopening of assessment - The High Court found that the Assessing Officer issued the notice based on the survey action on Jammu & Kashmir Bank, conducted after the original assessment order. The Court concluded that the notice was not issued due to any fresh tangible material but rather on the basis of the same material already available during the original assessment proceedings. The Court noted that the discrepancies in remittance amounts were explained by the bank's practice of applying notional and actual rates during transaction processing. The High Court quashed the notice issued under Section 148 of the Income Tax Act, 1961.
Validity of reopening of assessment - The High Court found that the Assessing Officer issued the notice based on the survey action on Jammu & Kashmir Bank, conducted after the original assessment order. The Court concluded that the notice was not issued due to any fresh tangible material but rather on the basis of the same material already available during the original assessment proceedings. The Court noted that the discrepancies in remittance amounts were explained by the bank's practice of applying notional and actual rates during transaction processing. The High Court quashed the notice issued under Section 148 of the Income Tax Act, 1961.
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