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AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether sub-rule (3) of rule 19A of the Income-tax Rules, 1962, was in direct conflict with section 80J of the Income-tax Act, 1961.
Analysis: The answer to the first question was agreed to be governed by the Supreme Court's ruling in Lohia Machines Ltd. and the subordinate rule was held not to prevail against the parent provision. The second question, being consequential, did not arise.
Conclusion: The first question was answered in the negative and in favour of the Revenue; the second question did not arise.
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