Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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