Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
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The ITAT Ahmedabad considered rectification u/s 154 for correct assessment year of DDT. Revenue argued DDT pertained to A.Y. 2014-15, but Section 115-O(3) mandates DDT payment when dividend is declared. DDT must be accounted for in the year it was paid. Assessee rectified Form 3CD for A.Y. 2014-15 and 2015-16 to correct DDT accounting error. CIT(A) rejected revised form, stating it should have been filed before end of relevant assessment year. However, as dividend declaration and DDT payment occurred in A.Y. 2015-16, DDT should be accounted for in A.Y. 2015-16. Assessee's appeal allowed.
The ITAT Ahmedabad considered rectification u/s 154 for correct assessment year of DDT. Revenue argued DDT pertained to A.Y. 2014-15, but Section 115-O(3) mandates DDT payment when dividend is declared. DDT must be accounted for in the year it was paid. Assessee rectified Form 3CD for A.Y. 2014-15 and 2015-16 to correct DDT accounting error. CIT(A) rejected revised form, stating it should have been filed before end of relevant assessment year. However, as dividend declaration and DDT payment occurred in A.Y. 2015-16, DDT should be accounted for in A.Y. 2015-16. Assessee's appeal allowed.
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