New LODR Fifth Amendment reshapes related party transaction rules, disclosure duties, and non-convertible security communication timelines under Sched...
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ITAT condoned the effective delay of 834 days in filing the appeals by the assessee, holding that sufficient cause existed within the meaning of S.5 of the Limitation Act, particularly in light of the exclusion of the period from 15.03.2020 to 28.02.2022 for limitation purposes as directed by the Apex Court. On merits, ITAT noted that the TDS demand raised u/s 200A(1) resulted from data entry errors in e-filing of TDS returns through NSDL, leading to TDS mismatch. Observing that the assessee's claim appeared genuine, ITAT set aside the impugned orders and remanded all five matters to the AO with directions to grant access to the CONSOLE file in the TDS module, allow reconciliation, and rectify mismatches in accordance with law.
ITAT condoned the effective delay of 834 days in filing the appeals by the assessee, holding that sufficient cause existed within the meaning of S.5 of the Limitation Act, particularly in light of the exclusion of the period from 15.03.2020 to 28.02.2022 for limitation purposes as directed by the Apex Court. On merits, ITAT noted that the TDS demand raised u/s 200A(1) resulted from data entry errors in e-filing of TDS returns through NSDL, leading to TDS mismatch. Observing that the assessee's claim appeared genuine, ITAT set aside the impugned orders and remanded all five matters to the AO with directions to grant access to the CONSOLE file in the TDS module, allow reconciliation, and rectify mismatches in accordance with law.
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