Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Revisional jurisdiction cannot serve as a substitute for filing a revised return after the statutory deadline. A fresh claim may be considered only where it raises a new question of law on foundational facts already before the Assessing Officer; claims requiring facts not placed before that authority fall outside revisional jurisdiction. The Tribunal's plenary appellate power to entertain a legal point does not expand the revisional authority's powers. This framework confines revision to the existing factual record and prevents its use to introduce a new fact-based tax claim.
Revisional jurisdiction cannot serve as a substitute for filing a revised return after the statutory deadline. A fresh claim may be considered only where it raises a new question of law on foundational facts already before the Assessing Officer; claims requiring facts not placed before that authority fall outside revisional jurisdiction. The Tribunal's plenary appellate power to entertain a legal point does not expand the revisional authority's powers. This framework confines revision to the existing factual record and prevents its use to introduce a new fact-based tax claim.
Note: It is a system-generated summary and is for quick reference only.