Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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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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