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...
The SC dismissed the Revenue's Special Leave Petition challenging the reopening of assessment under section 133A based on a survey of a bank. The petitioner's transactions with the bank involved inward and outward remittances, with discrepancies arising from the bank's use of both notional and actual realized exchange rates. The HC found that the petitioner had furnished all relevant material during the regular assessment, including bank statements reflecting actual realized rates, negating any prima facie belief of income escapement. The SC noted an unexplained inordinate delay of 198 days in filing and 79 days in refiling the SLP. On both procedural delay and substantive grounds, the SC upheld the High Court's order, concluding there was no justification to interfere with the assessment reopening. The petition was accordingly dismissed.
The SC dismissed the Revenue's Special Leave Petition challenging the reopening of assessment under section 133A based on a survey of a bank. The petitioner's transactions with the bank involved inward and outward remittances, with discrepancies arising from the bank's use of both notional and actual realized exchange rates. The HC found that the petitioner had furnished all relevant material during the regular assessment, including bank statements reflecting actual realized rates, negating any prima facie belief of income escapement. The SC noted an unexplained inordinate delay of 198 days in filing and 79 days in refiling the SLP. On both procedural delay and substantive grounds, the SC upheld the High Court's order, concluding there was no justification to interfere with the assessment reopening. The petition was accordingly dismissed.
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