notice u/s 271(1)(c)

[Mayank Raval]

Dear sirs.

My party has filled the return of income , comes under the scrutiny , in the matter A.O. found two points where he objected & made a addition to the matter.

Points are as under :

1. A.O. has demanded that my client has not ded. the TDS on source of the Loans taken from the Fin. Compnaies other than bank , here they have not made any TDS for the same.

2. My client has not given the effect of the cut off procedure for the expenditures to make proportion to the Prepaid Expenses in relation to the Insurance expenses and it involves Rs. 3 Lacs so here the A.O. has made the 60 % adhoc addition to the income.

Pls help me to resolve the case with some materials availabe to solve the matter.

Reagrds

Mayank 

AI Summary

Taxpayer Faces Additions for TDS and Prepaid Expenses; Possible Relief Under Section 271(1)(c) for No Intent to Evade A party filed an income tax return that was scrutinized by the Assessing Officer (A.O.), who raised two objections leading to additions. First, the client did not deduct TDS on loans from financial companies, not banks. Second, the client failed to proportion prepaid insurance expenses, resulting in a 60% adhoc addition to income. In response, an advisor suggested that relief might be possible under section 271(1)(c) if there was no intent to evade tax, as the additions were based on technical grounds, potentially allowing for the penalty to be waived.