Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Personal hearing requirements in GST adjudication were satisfied by prior opportunities and written submissions; appellate limitation received writ-pe...
The ITAT allowed the appeal of the assessee-trust, holding that the addition of Rs. 44,00,000/- made under s. 143(1) was unsustainable. The CPC had accepted all deductions claimed under ss. 11 and 10(23C), but committed an arithmetical error by incorrectly totaling the deductions at Rs. 7,52,41,564/- instead of Rs. 7,96,41,565/-. This miscalculation led to an erroneous computation of income purportedly chargeable under s. 11(1B), though the figure of Rs. 44,00,000/- was consistently reflected by both the assessee and CPC. ITAT held that the variation stemmed solely from CPC's totaling mistake, not from any disallowance or difference in claim, and therefore directed deletion of the entire addition.
The ITAT allowed the appeal of the assessee-trust, holding that the addition of Rs. 44,00,000/- made under s. 143(1) was unsustainable. The CPC had accepted all deductions claimed under ss. 11 and 10(23C), but committed an arithmetical error by incorrectly totaling the deductions at Rs. 7,52,41,564/- instead of Rs. 7,96,41,565/-. This miscalculation led to an erroneous computation of income purportedly chargeable under s. 11(1B), though the figure of Rs. 44,00,000/- was consistently reflected by both the assessee and CPC. ITAT held that the variation stemmed solely from CPC's totaling mistake, not from any disallowance or difference in claim, and therefore directed deletion of the entire addition.
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