Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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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