Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
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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...
Unabsorbed depreciation carried forward under Section 32(2) retains the character of current-year loss and may be set off against business income or other income, except capital gains; on that basis, the assessee was entitled to set off the depreciation against the addition made for unaccounted stock. The revenue's reliance on Section 79A failed because it was inserted later and applied only from 01.04.2022, and Section 115BBE(2) was also inapplicable because the assessment was not framed under that provision. The substantial questions of law were answered in favour of the assessee.
Unabsorbed depreciation carried forward under Section 32(2) retains the character of current-year loss and may be set off against business income or other income, except capital gains; on that basis, the assessee was entitled to set off the depreciation against the addition made for unaccounted stock. The revenue's reliance on Section 79A failed because it was inserted later and applied only from 01.04.2022, and Section 115BBE(2) was also inapplicable because the assessment was not framed under that provision. The substantial questions of law were answered in favour of the assessee.
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