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...
Reassessment notices issued u/s 148 for assessment years 2018-19, 2019-20, and 2020-21 were time-barred by limitation. Withdrawal of approval u/s 10(23C)(vi) by the Principal Commissioner of Income Tax (PCIT) was invalid as there were no valid pending proceedings before the Assessing Officer. The second proviso to section 143(3), allowing the Assessing Officer to make a reference, was applicable only from assessment year 2022-23 onwards. The PCIT lacked jurisdiction, as the Commissioner (Exemption) with territorial jurisdiction should have approved or withdrawn the approval. The Appellate Tribunal decided in favor of the assessee, quashing the PCIT's orders withdrawing approval u/s 10(23C)(vi) due to lack of jurisdiction and invalid reassessment proceedings.
Reassessment notices issued u/s 148 for assessment years 2018-19, 2019-20, and 2020-21 were time-barred by limitation. Withdrawal of approval u/s 10(23C)(vi) by the Principal Commissioner of Income Tax (PCIT) was invalid as there were no valid pending proceedings before the Assessing Officer. The second proviso to section 143(3), allowing the Assessing Officer to make a reference, was applicable only from assessment year 2022-23 onwards. The PCIT lacked jurisdiction, as the Commissioner (Exemption) with territorial jurisdiction should have approved or withdrawn the approval. The Appellate Tribunal decided in favor of the assessee, quashing the PCIT's orders withdrawing approval u/s 10(23C)(vi) due to lack of jurisdiction and invalid reassessment proceedings.
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