Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
The HC quashed the order rejecting the petitioner's application under s119(2)(b) of the Income Tax Act for condonation of delay in filing a corrected return. The petitioner had erroneously clubbed disallowances under s37 in column-23 instead of properly recording them in columns 15 and 18 of Form ITR-6. Since this was merely a presentation error with no impact on taxable income, and was made to facilitate CPC processing for potential refund, the Court held that the tax authority should have condoned the delay. The HC directed respondent to process the revised return filed on 06/09/2019 in accordance with law, emphasizing that the correction was a formality that did not alter the substantive tax position.
The HC quashed the order rejecting the petitioner's application under s119(2)(b) of the Income Tax Act for condonation of delay in filing a corrected return. The petitioner had erroneously clubbed disallowances under s37 in column-23 instead of properly recording them in columns 15 and 18 of Form ITR-6. Since this was merely a presentation error with no impact on taxable income, and was made to facilitate CPC processing for potential refund, the Court held that the tax authority should have condoned the delay. The HC directed respondent to process the revised return filed on 06/09/2019 in accordance with law, emphasizing that the correction was a formality that did not alter the substantive tax position.
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