SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
The ITAT held that the intimation under section 143(1) issued on 30.03.2019 was invalid as it was passed before the expiry of the mandatory 30-day period provided to the assessee for submitting a response, which ended on 22.04.2019. The purported response date of 23.03.2019 was found to be incorrect and inconsistent with the record. Consequently, the Tribunal ruled that the intimation was bad in law for non-compliance with the statutory procedural requirement. As a result, the disallowance made by the AO pursuant to the impugned intimation was deleted. The appeal filed by the assessee was allowed.
The ITAT held that the intimation under section 143(1) issued on 30.03.2019 was invalid as it was passed before the expiry of the mandatory 30-day period provided to the assessee for submitting a response, which ended on 22.04.2019. The purported response date of 23.03.2019 was found to be incorrect and inconsistent with the record. Consequently, the Tribunal ruled that the intimation was bad in law for non-compliance with the statutory procedural requirement. As a result, the disallowance made by the AO pursuant to the impugned intimation was deleted. The appeal filed by the assessee was allowed.
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