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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The assessment order passed u/s 144C(3) was beyond the prescribed period of one month from the end of the month in which the period for filing objections u/s 144C(2) expired. Although the assessee filed objections before the Dispute Resolution Panel beyond the 30-day period, the Assessing Officer was still required to pass the final order within the stipulated timeframe u/s 144C(4). The High Court upheld the Tribunal's decision to set aside the final assessment order as being time-barred, rejecting the Revenue's argument that the assessee cannot take advantage of its own delay in filing objections. The statutory language of Section 144C(4) is unambiguous, and the Assessing Officer's failure to comply with the time limit renders the order invalid, irrespective of the assessee's delay.
The assessment order passed u/s 144C(3) was beyond the prescribed period of one month from the end of the month in which the period for filing objections u/s 144C(2) expired. Although the assessee filed objections before the Dispute Resolution Panel beyond the 30-day period, the Assessing Officer was still required to pass the final order within the stipulated timeframe u/s 144C(4). The High Court upheld the Tribunal's decision to set aside the final assessment order as being time-barred, rejecting the Revenue's argument that the assessee cannot take advantage of its own delay in filing objections. The statutory language of Section 144C(4) is unambiguous, and the Assessing Officer's failure to comply with the time limit renders the order invalid, irrespective of the assessee's delay.
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