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...
The Appellate Tribunal concurred with the Mumbai Tribunal's order in M/s Pooja Marketing, which comprehensively dealt with all aspects, facts, and applicable case laws. The bench not only considered the validity of revisionary jurisdiction u/s 263 but also decided the issue on merits in favor of the assessee. The case law in CIT vs. Dr. M.A.M. Ramaswamy was distinguished by the learned Senior Counsel in written submissions, which was deliberated upon and found concurrence. No distinguishing feature or reversal of the Mumbai Tribunal's decision by higher judicial authorities was shown. The Tribunal dismissed the revenue's appeal after elaborately dealing with the issue on merits.
The Appellate Tribunal concurred with the Mumbai Tribunal's order in M/s Pooja Marketing, which comprehensively dealt with all aspects, facts, and applicable case laws. The bench not only considered the validity of revisionary jurisdiction u/s 263 but also decided the issue on merits in favor of the assessee. The case law in CIT vs. Dr. M.A.M. Ramaswamy was distinguished by the learned Senior Counsel in written submissions, which was deliberated upon and found concurrence. No distinguishing feature or reversal of the Mumbai Tribunal's decision by higher judicial authorities was shown. The Tribunal dismissed the revenue's appeal after elaborately dealing with the issue on merits.
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