Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Admission of additional evidence under Rule 29 of ITAT Rules was allowed and admitted. Non-deduction of tax at source was considered: for two payees, production and departmental verification of TDS certificates established that the assessee is not in default, and the demand under section 201(1) and interest under section 201(1A) relating to those payments were deleted. For two other payees, a 30% disallowance of expenditure for non-deduction was upheld and the Assessing Officer was directed to recompute any liability accordingly. Verification of TDS return filing was ordered and fee under section 234E to be deleted if return was timely.
Admission of additional evidence under Rule 29 of ITAT Rules was allowed and admitted. Non-deduction of tax at source was considered: for two payees, production and departmental verification of TDS certificates established that the assessee is not in default, and the demand under section 201(1) and interest under section 201(1A) relating to those payments were deleted. For two other payees, a 30% disallowance of expenditure for non-deduction was upheld and the Assessing Officer was directed to recompute any liability accordingly. Verification of TDS return filing was ordered and fee under section 234E to be deleted if return was timely.
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