Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
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HC dismissed petition seeking permission to file revised return beyond limitation period. Petitioner claimed additional TDS credit of Rs. 1,83,770 (difference between Rs. 2,69,338 and Rs. 85,568) for AY 2012-13 due to subsequent crediting of TDS on works contract by Government employer. Court held that delay condonation under CBDT Circular not applicable as limitation period u/s 148 read with Section 151 of Income Tax Act had expired. TDS credited in subsequent year can only be utilized for succeeding assessment year. Attempt to enhance taxable income through revised return for additional refund was rejected as time-barred.
HC dismissed petition seeking permission to file revised return beyond limitation period. Petitioner claimed additional TDS credit of Rs. 1,83,770 (difference between Rs. 2,69,338 and Rs. 85,568) for AY 2012-13 due to subsequent crediting of TDS on works contract by Government employer. Court held that delay condonation under CBDT Circular not applicable as limitation period u/s 148 read with Section 151 of Income Tax Act had expired. TDS credited in subsequent year can only be utilized for succeeding assessment year. Attempt to enhance taxable income through revised return for additional refund was rejected as time-barred.
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