Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
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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