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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A High Court held that a Dispute Resolution Panel direction was binding and could not be ignored by the Assessing Officer. Because no departmental appeal had been filed on the earlier years' issue, the addition made under section 40(a)(i) was contrary to the DRP's clear mandate and could not be sustained. The Court therefore exercised writ jurisdiction to quash the demand, including interest, relatable to that addition, despite the availability of an alternate appellate remedy. The remaining transfer pricing adjustment was left open to challenge in the ordinary appeal, with protection against limitation if filed within the time granted.
A High Court held that a Dispute Resolution Panel direction was binding and could not be ignored by the Assessing Officer. Because no departmental appeal had been filed on the earlier years' issue, the addition made under section 40(a)(i) was contrary to the DRP's clear mandate and could not be sustained. The Court therefore exercised writ jurisdiction to quash the demand, including interest, relatable to that addition, despite the availability of an alternate appellate remedy. The remaining transfer pricing adjustment was left open to challenge in the ordinary appeal, with protection against limitation if filed within the time granted.
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