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Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
The case involves rectification u/s 154 for disallowance of bad debts provisions u/s 36(1)(viia) in a co-operative bank's computation sheet. ITAT held that the mistake was apparent as the provision was not in the books. CIT(A) noted rectification requires a glaring mistake of law. ITAT found the claim ineligible and rectified u/s 154. CIT(A) noted a similar deduction in a subsequent year but the provision was duly accounted for. AR argued for deduction based on Companies Act provisions, but ITAT found no support for allowing the claim if not in books. Following precedent, ITAT remitted the matter to AO to allow deduction based on actual provision made in books. Revenue's appeal partly allowed for statistical purposes.
The case involves rectification u/s 154 for disallowance of bad debts provisions u/s 36(1)(viia) in a co-operative bank's computation sheet. ITAT held that the mistake was apparent as the provision was not in the books. CIT(A) noted rectification requires a glaring mistake of law. ITAT found the claim ineligible and rectified u/s 154. CIT(A) noted a similar deduction in a subsequent year but the provision was duly accounted for. AR argued for deduction based on Companies Act provisions, but ITAT found no support for allowing the claim if not in books. Following precedent, ITAT remitted the matter to AO to allow deduction based on actual provision made in books. Revenue's appeal partly allowed for statistical purposes.
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