Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
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...
The Income Tax Appellate Tribunal held that when the assessing officer considered undisclosed income based on seized material, they ought to have also considered undisclosed losses from the same material and allowed set-off. Failing to do so constituted a mistake apparent from record u/s 254(2). The Tribunal directed the assessing officer to allow set-off of undisclosed losses of the immediately preceding year against the undisclosed income for the impugned year, following principles of equity, justice and interpreting seized material as a whole.
The Income Tax Appellate Tribunal held that when the assessing officer considered undisclosed income based on seized material, they ought to have also considered undisclosed losses from the same material and allowed set-off. Failing to do so constituted a mistake apparent from record u/s 254(2). The Tribunal directed the assessing officer to allow set-off of undisclosed losses of the immediately preceding year against the undisclosed income for the impugned year, following principles of equity, justice and interpreting seized material as a whole.
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