Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
Inordinate delay of about 11 years was not condoned because a vague explanation based on ignorance of tax procedure, wrong advice and change of consultant did not show sufficient cause for the entire period; the appeal was therefore time-barred and not examined on merits. On the double taxation issue, the Tribunal accepted that the surrendered income in AY 2010-11 appeared to have been taxed again in reopened earlier years, applied the rule that the same income can be taxed only once, and directed deletion of the addition subject to verification that the amounts were identical.
Inordinate delay of about 11 years was not condoned because a vague explanation based on ignorance of tax procedure, wrong advice and change of consultant did not show sufficient cause for the entire period; the appeal was therefore time-barred and not examined on merits. On the double taxation issue, the Tribunal accepted that the surrendered income in AY 2010-11 appeared to have been taxed again in reopened earlier years, applied the rule that the same income can be taxed only once, and directed deletion of the addition subject to verification that the amounts were identical.
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