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The ITAT addressed multiple issues concerning an eligible assessee under section 144C(15)(b). Regarding service of draft assessment order, the tribunal held that despite improper email service, the assessee's participation in proceedings and timely filing of objections before DRP precluded challenges to service validity, citing Supreme Court precedent in CIT vs. Laxman Das Khandelwal. For CESS disallowance under section 40(a)(ii), the tribunal found AO and DRP findings cryptic and contrary to record facts, noting the expenditure related to PSC conditions rather than education cess. The matter was remanded to AO for examining past treatment consistency. Similarly, issues regarding Other Business and Community Development expenditure as CSR expenses and Seismic, Geological and Reservoir Studies classification were remanded to AO for verification of previous years' treatment, applying consistency principle for revenue recognition.
The ITAT addressed multiple issues concerning an eligible assessee under section 144C(15)(b). Regarding service of draft assessment order, the tribunal held that despite improper email service, the assessee's participation in proceedings and timely filing of objections before DRP precluded challenges to service validity, citing Supreme Court precedent in CIT vs. Laxman Das Khandelwal. For CESS disallowance under section 40(a)(ii), the tribunal found AO and DRP findings cryptic and contrary to record facts, noting the expenditure related to PSC conditions rather than education cess. The matter was remanded to AO for examining past treatment consistency. Similarly, issues regarding Other Business and Community Development expenditure as CSR expenses and Seismic, Geological and Reservoir Studies classification were remanded to AO for verification of previous years' treatment, applying consistency principle for revenue recognition.
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