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...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Reopening of assessment - Reasons to believe - ACIT jurisdiction to issue the notice u/s 148 - The Tribunal concluded that the reasons for reopening were based on credible information from the Investigation Wing, providing sufficient grounds for prima facie belief of income escapement. The approval from the PCIT, although brief, was considered valid as there was no evidence indicating lack of proper application of mind. - The Tribunal rejected the appellant's argument about the notice being issued after the prescribed time limit, noting that the acknowledgment from the postal authorities confirmed receipt within the deadline. Objections regarding reasons for issuing notices under section 143(2) and inadequate time for compliance were deemed meritless.
Reopening of assessment - Reasons to believe - ACIT jurisdiction to issue the notice u/s 148 - The Tribunal concluded that the reasons for reopening were based on credible information from the Investigation Wing, providing sufficient grounds for prima facie belief of income escapement. The approval from the PCIT, although brief, was considered valid as there was no evidence indicating lack of proper application of mind. - The Tribunal rejected the appellant's argument about the notice being issued after the prescribed time limit, noting that the acknowledgment from the postal authorities confirmed receipt within the deadline. Objections regarding reasons for issuing notices under section 143(2) and inadequate time for compliance were deemed meritless.
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