Condonation of delay in filing GSTR-3B returns and entitlement to Section 62 benefit results in withdrawal of assessments and revocation of attachment...
Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
Managerial remuneration disallowance under s.40A(2)(b) challenged over alleged tax-avoidance; appellate decision restored deletion of addition for dir...
TDS under s. 194C is attracted at the earlier of credit or payment. Since the liability for external development charges arose on credit in AY 2012-13, any default under s. 201(1) and interest under s. 201(1A) could be fastened only for AY 2012-13; the assessee could not be treated as an assessee-in-default for AY 2014-15 for the same amounts. Further, applying s. 201(3), the limitation ran from the relevant credit event, and the last date to pass an order was 31-03-2019; the order dated 25-03-2021 was time-barred and was set aside. - ITAT
TDS under s. 194C is attracted at the earlier of credit or payment. Since the liability for external development charges arose on credit in AY 2012-13, any default under s. 201(1) and interest under s. 201(1A) could be fastened only for AY 2012-13; the assessee could not be treated as an assessee-in-default for AY 2014-15 for the same amounts. Further, applying s. 201(3), the limitation ran from the relevant credit event, and the last date to pass an order was 31-03-2019; the order dated 25-03-2021 was time-barred and was set aside. - ITAT
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