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...
A single adjudication order creating tax and penalty liability cannot be split through separate DRC-07 notices so as to force multiple appeals or an additional pre-deposit toward penalty. The statutory appeal mechanism is satisfied by one appeal against the composite order on deposit of 10% of the disputed tax demand, without any further deposit at that stage for the penalty component. The Court permitted withdrawal of the two notices and issuance of a fresh composite DRC-07, and clarified that limitation for appeal would run from service of the fresh notice, with no further recovery pending compliance.
A single adjudication order creating tax and penalty liability cannot be split through separate DRC-07 notices so as to force multiple appeals or an additional pre-deposit toward penalty. The statutory appeal mechanism is satisfied by one appeal against the composite order on deposit of 10% of the disputed tax demand, without any further deposit at that stage for the penalty component. The Court permitted withdrawal of the two notices and issuance of a fresh composite DRC-07, and clarified that limitation for appeal would run from service of the fresh notice, with no further recovery pending compliance.
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