Consultancy fees claimed as business expense-can tax disallowance rest on survey suspicion despite invoices, contracts and bank trail? Appeal dismisse...
Whether assessing officers must verify claimed TDS credits and whether courts may direct automated software changes to prevent demands: the Court held that the Assessing Officer must examine factual records before waiving liability for undeposited TDS, since technology aids processing but cannot replace adjudication; therefore verification and, where necessary, show-cause procedures remain essential - outcome: AO's verification duty affirmed. Whether High Court could order departmental software modifications and automatic non-raising of demands: the Court held such directions intrude on adjudicatory functions and risk ignoring genuine demands - outcome: directions to modify the software were set aside. - SC
Whether assessing officers must verify claimed TDS credits and whether courts may direct automated software changes to prevent demands: the Court held that the Assessing Officer must examine factual records before waiving liability for undeposited TDS, since technology aids processing but cannot replace adjudication; therefore verification and, where necessary, show-cause procedures remain essential - outcome: AO's verification duty affirmed. Whether High Court could order departmental software modifications and automatic non-raising of demands: the Court held such directions intrude on adjudicatory functions and risk ignoring genuine demands - outcome: directions to modify the software were set aside. - SC
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