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ITAT rejected assessee's challenge to assessment order validity based on multiple DINs, holding that multiple DINs arose from inadvertent system migration errors between ITD/AST and ITBA-Portal systems, not from delayed assessment beyond statutory deadline of 31.12.2019. Tribunal ruled assessment order was timely passed and not barred by limitation. Regarding substantive additions, ITAT allowed appeal partially by directing deletion of additions under section 40(a)(iib) for privilege fees, special privilege fees, additional privilege fees, and CM Relief Fund contributions, finding these constituted income diversion by overriding title rather than taxable income. Tribunal also deleted duplicate additions made on same receipt. However, ITAT upheld disallowances for leave encashment, PF, superannuation, and gratuity due to lack of documentary evidence. Interest under sections 234B and 234C to be recomputed accordingly.
ITAT rejected assessee's challenge to assessment order validity based on multiple DINs, holding that multiple DINs arose from inadvertent system migration errors between ITD/AST and ITBA-Portal systems, not from delayed assessment beyond statutory deadline of 31.12.2019. Tribunal ruled assessment order was timely passed and not barred by limitation. Regarding substantive additions, ITAT allowed appeal partially by directing deletion of additions under section 40(a)(iib) for privilege fees, special privilege fees, additional privilege fees, and CM Relief Fund contributions, finding these constituted income diversion by overriding title rather than taxable income. Tribunal also deleted duplicate additions made on same receipt. However, ITAT upheld disallowances for leave encashment, PF, superannuation, and gratuity due to lack of documentary evidence. Interest under sections 234B and 234C to be recomputed accordingly.
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