Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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...
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Bogus Purchases - Credibility of Statements - The tribunal was not convinced by the appellant's argument that the initial statements were made under duress or misinterpreted. They emphasized that the retraction came after substantial delay and seemed more like an afterthought designed to escape tax liability. - Despite the retraction, the tribunal held that the original statements admitting to bogus purchases and additional income were credible. They relied on the timing of the retraction and the specifics of the declarations made during the survey. The admissions of additional income were deemed to substantiate the reopening of assessments for the years in question. The tribunal supported the additions made to the taxable income based on these declarations.
Bogus Purchases - Credibility of Statements - The tribunal was not convinced by the appellant's argument that the initial statements were made under duress or misinterpreted. They emphasized that the retraction came after substantial delay and seemed more like an afterthought designed to escape tax liability. - Despite the retraction, the tribunal held that the original statements admitting to bogus purchases and additional income were credible. They relied on the timing of the retraction and the specifics of the declarations made during the survey. The admissions of additional income were deemed to substantiate the reopening of assessments for the years in question. The tribunal supported the additions made to the taxable income based on these declarations.
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