Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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...
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Where a scrutiny assessment under section 143(3) expressly accepted the returned income and made no addition or disallowance, the computation sheet could not override the assessment order. Once the regular assessment was completed, the earlier intimation under section 143(1) merged into it and lost independent existence, so the Assessing Officer could not rely on that earlier adjustment to justify a higher assessed income. The Tribunal further held that revising total income on these facts was not a mistake apparent from the record but a substantive re-determination of income, making section 154 unavailable. The rectification order was therefore unsustainable and the income had to remain as determined in the scrutiny assessment.
Where a scrutiny assessment under section 143(3) expressly accepted the returned income and made no addition or disallowance, the computation sheet could not override the assessment order. Once the regular assessment was completed, the earlier intimation under section 143(1) merged into it and lost independent existence, so the Assessing Officer could not rely on that earlier adjustment to justify a higher assessed income. The Tribunal further held that revising total income on these facts was not a mistake apparent from the record but a substantive re-determination of income, making section 154 unavailable. The rectification order was therefore unsustainable and the income had to remain as determined in the scrutiny assessment.
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