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...
SC addressed the validity of reassessment notices where the decisive question was whether the matters related to Assessment Year 2015-16. It recorded the Revenue's concession that, for that year, reassessment notices would be time-barred in light of Rajeev Bansal; if a case falls in that year, the notices must be struck down without further adjudication. If the matters relate to any other assessment year, the assessees may raise all contentions available under the earlier order, and the High Courts must decide the cases accordingly. The impugned judgments were set aside and the matters remitted for fresh determination on that threshold issue first.
SC addressed the validity of reassessment notices where the decisive question was whether the matters related to Assessment Year 2015-16. It recorded the Revenue's concession that, for that year, reassessment notices would be time-barred in light of Rajeev Bansal; if a case falls in that year, the notices must be struck down without further adjudication. If the matters relate to any other assessment year, the assessees may raise all contentions available under the earlier order, and the High Courts must decide the cases accordingly. The impugned judgments were set aside and the matters remitted for fresh determination on that threshold issue first.
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