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...
Income from sale of assets of a bank under liquidation was held not to be diverted at source by overriding title in favour of DICGC; the income accrued to the official liquidator, and the claim of no taxable accrual was rejected. In rectification proceedings, the Tribunal held that the set-off of deemed short-term capital gain on depreciable assets against brought forward business loss was a debatable issue and could not be corrected as an apparent mistake under section 154; the rectification order was quashed. It also held that a bad debt written off in the ordinary course of banking business satisfied the statutory conditions, and actual proof of irrecoverability was not required once the write-off was made; the disallowance was deleted.
Income from sale of assets of a bank under liquidation was held not to be diverted at source by overriding title in favour of DICGC; the income accrued to the official liquidator, and the claim of no taxable accrual was rejected. In rectification proceedings, the Tribunal held that the set-off of deemed short-term capital gain on depreciable assets against brought forward business loss was a debatable issue and could not be corrected as an apparent mistake under section 154; the rectification order was quashed. It also held that a bad debt written off in the ordinary course of banking business satisfied the statutory conditions, and actual proof of irrecoverability was not required once the write-off was made; the disallowance was deleted.
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