Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
The ITAT held that corrected TDS statements filed before the later amendment could not be treated as time-barred, because no specific filing limit then applied, and the amendment in the Finance (No. 2) Act, 2024 could not operate retrospectively. It also held that an appeal lay against the rectification order itself, so dismissal by the first appellate authority on limitation was unsustainable. On merits, the Tribunal held that fee under section 234E could not be levied through processing under section 200A for periods before 01.06.2015, because the enabling machinery came into force only from that date; the fee was deleted.
The ITAT held that corrected TDS statements filed before the later amendment could not be treated as time-barred, because no specific filing limit then applied, and the amendment in the Finance (No. 2) Act, 2024 could not operate retrospectively. It also held that an appeal lay against the rectification order itself, so dismissal by the first appellate authority on limitation was unsustainable. On merits, the Tribunal held that fee under section 234E could not be levied through processing under section 200A for periods before 01.06.2015, because the enabling machinery came into force only from that date; the fee was deleted.
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