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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...
Delay and laches can defeat a request for interim protection against recovery proceedings where the party waits to approach the Court after receiving an initial notice threatening coercive action. The Court noted that the petitioner had already replied with objections to the notice, so any challenge to the proposed recovery and alleged non-consideration of the representation should have been made promptly at that stage. Because the petition was filed only after later recovery notices were issued, the delay was treated as unjustified for interim relief. Interim protection was refused, while the petition remained pending and the respondents were asked to explain the non-consideration of the representation and the timing of the recovery action.
Delay and laches can defeat a request for interim protection against recovery proceedings where the party waits to approach the Court after receiving an initial notice threatening coercive action. The Court noted that the petitioner had already replied with objections to the notice, so any challenge to the proposed recovery and alleged non-consideration of the representation should have been made promptly at that stage. Because the petition was filed only after later recovery notices were issued, the delay was treated as unjustified for interim relief. Interim protection was refused, while the petition remained pending and the respondents were asked to explain the non-consideration of the representation and the timing of the recovery action.
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