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 ruling on tax reassessment for AY 2014-2015: The court held that the reassessment notice under Section 148 was invalid. The AO's reopening of assessment was deemed a mere change of opinion rather than discovery of new material, as the original assessment was based on search operation materials. The court found that the materials used for reopening were already part of the original assessment proceedings. Consequently, the court set aside the reassessment notice dated 31.03.2021 and the order rejecting objections dated 21.02.2022, effectively allowing the writ petition and invalidating the reassessment proceedings.
HC ruling on tax reassessment for AY 2014-2015: The court held that the reassessment notice under Section 148 was invalid. The AO's reopening of assessment was deemed a mere change of opinion rather than discovery of new material, as the original assessment was based on search operation materials. The court found that the materials used for reopening were already part of the original assessment proceedings. Consequently, the court set aside the reassessment notice dated 31.03.2021 and the order rejecting objections dated 21.02.2022, effectively allowing the writ petition and invalidating the reassessment proceedings.
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