Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Section 154 rectification applications must be filed within four years from the end of the financial year in which the order sought to be amended was passed. The notes state that section 154(7) is clear and unambiguous and contains no provision allowing condonation of delay for reasonable cause. On a literal construction, expiry of this period removes the authority's jurisdiction to entertain a rectification application, including applications seeking correction of income returned and processed under section 143(1). Accordingly, the delayed applications were treated as time-barred, their rejection was upheld, and the related appeals were dismissed.
Section 154 rectification applications must be filed within four years from the end of the financial year in which the order sought to be amended was passed. The notes state that section 154(7) is clear and unambiguous and contains no provision allowing condonation of delay for reasonable cause. On a literal construction, expiry of this period removes the authority's jurisdiction to entertain a rectification application, including applications seeking correction of income returned and processed under section 143(1). Accordingly, the delayed applications were treated as time-barred, their rejection was upheld, and the related appeals were dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4782
Join Channel
TaxTMI 
