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...
SC allowed appeal against rejection of compounding application for offense under s.276CC for delayed tax return filing. Court held offense under s.276CC is committed day after due date under s.139(1), not on actual filing date. For AY 2013-14, offense occurred on 01.11.2013, before show cause notice dated 27.10.2014 for AY 2011-12 offense. This qualified as "first offense" under 2014 Compounding Guidelines. Court noted evolution toward more flexible compounding regime, with s.276CC now Category A offense allowing up to three compounding occasions. Orders of HC and CCIT rejected, appellant directed to file fresh compounding application within two weeks.
SC allowed appeal against rejection of compounding application for offense under s.276CC for delayed tax return filing. Court held offense under s.276CC is committed day after due date under s.139(1), not on actual filing date. For AY 2013-14, offense occurred on 01.11.2013, before show cause notice dated 27.10.2014 for AY 2011-12 offense. This qualified as "first offense" under 2014 Compounding Guidelines. Court noted evolution toward more flexible compounding regime, with s.276CC now Category A offense allowing up to three compounding occasions. Orders of HC and CCIT rejected, appellant directed to file fresh compounding application within two weeks.
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