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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The HC dismissed the petition and upheld the validity of the impugned show-cause notice issued to the transferor company, holding that the notice is not shown to be wholly without jurisdiction; factual and jurisdictional questions relating to the demerger and retrospective operation of the 2018 Notification require examination and cannot be summarily struck down. The Respondents are entitled to consider the demerger particulars and the applicability of the 2018 Notification when adjudicating the SCN, and the Petitioners are relegated to file a detailed response with full particulars and exhaust statutory remedies. The court found no exceptional circumstance to preclude adjudication or to quash the SCN at the threshold.
The HC dismissed the petition and upheld the validity of the impugned show-cause notice issued to the transferor company, holding that the notice is not shown to be wholly without jurisdiction; factual and jurisdictional questions relating to the demerger and retrospective operation of the 2018 Notification require examination and cannot be summarily struck down. The Respondents are entitled to consider the demerger particulars and the applicability of the 2018 Notification when adjudicating the SCN, and the Petitioners are relegated to file a detailed response with full particulars and exhaust statutory remedies. The court found no exceptional circumstance to preclude adjudication or to quash the SCN at the threshold.
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