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...
Income-tax search material can be relied on in benami proceedings absent any statutory bar, and the fact that the material originated in tax proceedings does not require a separate independent enquiry as a precondition to benami adjudication. The Tribunal held that routed accommodation entries, supported by connected statements and corroborating electronic records, established a benami transaction; retraction alone did not displace those statements where no satisfactory basis for retraction was shown. It also held that income-tax assessment and benami adjudication operate in distinct fields, so tax treatment of undisclosed income does not preclude a parallel benami finding. The provisional attachment was therefore sustained and the appeals were dismissed.
Income-tax search material can be relied on in benami proceedings absent any statutory bar, and the fact that the material originated in tax proceedings does not require a separate independent enquiry as a precondition to benami adjudication. The Tribunal held that routed accommodation entries, supported by connected statements and corroborating electronic records, established a benami transaction; retraction alone did not displace those statements where no satisfactory basis for retraction was shown. It also held that income-tax assessment and benami adjudication operate in distinct fields, so tax treatment of undisclosed income does not preclude a parallel benami finding. The provisional attachment was therefore sustained and the appeals were dismissed.
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