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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HC held that the tax authority's reopening of assessment against the mutual fund was invalid. The notice contained discrepancies between alleged fund manipulation and actual transaction details. Relying on precedent in a similar case involving JM Financial, the court found no substantive basis for reassessment. The jurisdictional defect in the reopening process rendered the Section 148A notice and subsequent order unsustainable. Consequently, the impugned notice and order were quashed, effectively allowing the assessee's appeal and nullifying the attempted reassessment.
HC held that the tax authority's reopening of assessment against the mutual fund was invalid. The notice contained discrepancies between alleged fund manipulation and actual transaction details. Relying on precedent in a similar case involving JM Financial, the court found no substantive basis for reassessment. The jurisdictional defect in the reopening process rendered the Section 148A notice and subsequent order unsustainable. Consequently, the impugned notice and order were quashed, effectively allowing the assessee's appeal and nullifying the attempted reassessment.
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