Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Disallowance u/s 80P - claim disallowed u/sec. 143(1)(a)(ii) by way of “processing” as an instance of “incorrect claim if such incorrect claim is there from any information in the return” - ITAT noted that this provision was applicable prospectively from April 1, 2021, while the assessment year in question was 2019-2020. Thus, the Tribunal concluded that this provision could not be applied retroactively to disallow the assessee’s deduction claim. - Relying on the principle of stricter interpretation as established in Commissioner vs. Dilip Kumar And Co. & Ors., the Tribunal concluded that the disallowance of the deduction claim by the lower authorities was not justified.
Disallowance u/s 80P - claim disallowed u/sec. 143(1)(a)(ii) by way of “processing” as an instance of “incorrect claim if such incorrect claim is there from any information in the return” - ITAT noted that this provision was applicable prospectively from April 1, 2021, while the assessment year in question was 2019-2020. Thus, the Tribunal concluded that this provision could not be applied retroactively to disallow the assessee’s deduction claim. - Relying on the principle of stricter interpretation as established in Commissioner vs. Dilip Kumar And Co. & Ors., the Tribunal concluded that the disallowance of the deduction claim by the lower authorities was not justified.
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