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...
HC held that for calculating the 6-year limitation period under Section 153C(1), the relevant date is 30.06.2022, when documents were collected from the petitioner, not the search date of 10.11.2020. The show cause notice dated 30.12.2024 is within limitation. The petitioner retains the right to respond to the notice and contest proceedings. Despite a prior settlement, the Department retains liberty to pursue further action if new materials emerge. The writ petitions were consequently dismissed, finding no merit in the petitioner's limitation arguments.
HC held that for calculating the 6-year limitation period under Section 153C(1), the relevant date is 30.06.2022, when documents were collected from the petitioner, not the search date of 10.11.2020. The show cause notice dated 30.12.2024 is within limitation. The petitioner retains the right to respond to the notice and contest proceedings. Despite a prior settlement, the Department retains liberty to pursue further action if new materials emerge. The writ petitions were consequently dismissed, finding no merit in the petitioner's limitation arguments.
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