Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
ITAT upholds CIT(A)'s dismissal of the second appeal, concluding the taxpayer is barred from a separate appellate remedy against the same assessment order. The taxpayer's challenge to an addition under s.2(22)(e) as causing double taxation was not entertained because the first appeal against the assessment had been adjudicated on merits, precluding re-litigation by a subsequent appeal. The application for revision/rectification under s.264 filed after more than four years was time-barred and the PCIT's refusal to condone delay was not challenged. The Tribunal found the judicial authority relied upon inapposite where first appeals were dismissed on technical grounds, and accordingly dismissed the taxpayer's second appeal.
ITAT upholds CIT(A)'s dismissal of the second appeal, concluding the taxpayer is barred from a separate appellate remedy against the same assessment order. The taxpayer's challenge to an addition under s.2(22)(e) as causing double taxation was not entertained because the first appeal against the assessment had been adjudicated on merits, precluding re-litigation by a subsequent appeal. The application for revision/rectification under s.264 filed after more than four years was time-barred and the PCIT's refusal to condone delay was not challenged. The Tribunal found the judicial authority relied upon inapposite where first appeals were dismissed on technical grounds, and accordingly dismissed the taxpayer's second appeal.
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