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Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Taxability of distribution fee earned for granting BBC News Channel distribution rights was not decided on merits, as the assessee had raised a fresh claim before the appellate stage after originally offering the amount to tax. Taking note of the CBDT circular that only legitimate tax should be assessed and collected, the ITAT restored the matter to the Jurisdictional Assessing Officer for de novo consideration on merits, with due opportunity of hearing to the assessee. The appeal was allowed for statistical purposes, and the question of tax liability remained open.
Taxability of distribution fee earned for granting BBC News Channel distribution rights was not decided on merits, as the assessee had raised a fresh claim before the appellate stage after originally offering the amount to tax. Taking note of the CBDT circular that only legitimate tax should be assessed and collected, the ITAT restored the matter to the Jurisdictional Assessing Officer for de novo consideration on merits, with due opportunity of hearing to the assessee. The appeal was allowed for statistical purposes, and the question of tax liability remained open.
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