Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
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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