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...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
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In a penalty matter under section 271D, the ITAT held that limitation under section 275(1)(c) runs from the Assessing Officer's reference initiating penalty action, not from the later notice issued by the Additional Commissioner. After noting conflicting High Court views, it followed the later Karnataka High Court position and also applied the principle that, where two non-jurisdictional interpretations are possible, the one favourable to the assessee must be adopted. As the penalty order was passed beyond the permissible period from the date of initiation, the penalty was time-barred and was quashed.
In a penalty matter under section 271D, the ITAT held that limitation under section 275(1)(c) runs from the Assessing Officer's reference initiating penalty action, not from the later notice issued by the Additional Commissioner. After noting conflicting High Court views, it followed the later Karnataka High Court position and also applied the principle that, where two non-jurisdictional interpretations are possible, the one favourable to the assessee must be adopted. As the penalty order was passed beyond the permissible period from the date of initiation, the penalty was time-barred and was quashed.
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