Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
Revisional jurisdiction over export quota premium deductions requires both error and Revenue prejudice; a permissible assessment view cannot be displa...
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Revised tax audit reports and corresponding revised returns filed before processing under section 143(1) require consideration despite filing after the prescribed due date where they correct disallowances based on Form 26A. Form 26A activates statutory relief from disallowance for non-deduction of tax at source, and the same expenditure cannot be disallowed again under section 40(a)(ia) after disallowance under section 43B(da). Rule 46A(3) does not require remand when materials were electronically furnished before processing and no fresh appellate evidence is admitted. After deletion of adjustments, set-off of brought-forward losses is academic where no positive income remains.
Revised tax audit reports and corresponding revised returns filed before processing under section 143(1) require consideration despite filing after the prescribed due date where they correct disallowances based on Form 26A. Form 26A activates statutory relief from disallowance for non-deduction of tax at source, and the same expenditure cannot be disallowed again under section 40(a)(ia) after disallowance under section 43B(da). Rule 46A(3) does not require remand when materials were electronically furnished before processing and no fresh appellate evidence is admitted. After deletion of adjustments, set-off of brought-forward losses is academic where no positive income remains.
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