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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The ITAT upheld the CPC's authority under section 200A(2) to levy late fees u/s 234E and interest u/s 201 for delayed filing and non-deposit of TDS statements. While section 200A(2) uses the term "tax payable," the Tribunal interpreted this to encompass the broader "sum payable," including fees and interest. The CPC's scheme for centralised processing aims to streamline TDS return handling, replacing Assessing Officers' functions. The Tribunal rejected the assessee's contention that CPC lacked power to impose fees and interest, emphasizing the statutory scheme's intent and provisions. Consequently, the appeal challenging the levy of late fees and interest by CPC was dismissed, affirming the validity of CPC's actions under the Income Tax Act.
The ITAT upheld the CPC's authority under section 200A(2) to levy late fees u/s 234E and interest u/s 201 for delayed filing and non-deposit of TDS statements. While section 200A(2) uses the term "tax payable," the Tribunal interpreted this to encompass the broader "sum payable," including fees and interest. The CPC's scheme for centralised processing aims to streamline TDS return handling, replacing Assessing Officers' functions. The Tribunal rejected the assessee's contention that CPC lacked power to impose fees and interest, emphasizing the statutory scheme's intent and provisions. Consequently, the appeal challenging the levy of late fees and interest by CPC was dismissed, affirming the validity of CPC's actions under the Income Tax Act.
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