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...
ITAT condoned a 267-day delay, admitted the appeal and allowed the assessee's challenge to a revision order under s.263. Holding that the PCIT acted without independent application of mind, failed to appreciate the distinction between substantive and protective assessments and overlooked pending appellate proceedings, the Tribunal quashed the impugned s.263 order and restored the assessment framed by the AO under s.147/ s.143(3). The Tribunal found the addition under s.68 in the related entity's substantive assessment preclusive of revising the assessee's protective assessment, concluded no mala fide conduct or investigation failure, and remitted no further relief; the assessee's appeal accordingly succeeds.
ITAT condoned a 267-day delay, admitted the appeal and allowed the assessee's challenge to a revision order under s.263. Holding that the PCIT acted without independent application of mind, failed to appreciate the distinction between substantive and protective assessments and overlooked pending appellate proceedings, the Tribunal quashed the impugned s.263 order and restored the assessment framed by the AO under s.147/ s.143(3). The Tribunal found the addition under s.68 in the related entity's substantive assessment preclusive of revising the assessee's protective assessment, concluded no mala fide conduct or investigation failure, and remitted no further relief; the assessee's appeal accordingly succeeds.
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