Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Disallowance under section 40(a)(ia) for alleged non deduction of TDS on contractual payments was rejected after appellate verification of party wise ledgers, TDS returns, certificates and tax audit reports; appellate authority found tax deducted where applicable and set aside the assessing officer's blanket disallowance. Alleged nondisclosure based on Form 26AS entries and invocation of section 145(3) was also rejected because the AO relied on incorrect or double counted figures and ignored reconciliations and the assessee's percentage of completion accounting; the appellate authority's acceptance of reconciliations led to deletion of the addition. Both revenue grounds were dismissed.
Disallowance under section 40(a)(ia) for alleged non deduction of TDS on contractual payments was rejected after appellate verification of party wise ledgers, TDS returns, certificates and tax audit reports; appellate authority found tax deducted where applicable and set aside the assessing officer's blanket disallowance. Alleged nondisclosure based on Form 26AS entries and invocation of section 145(3) was also rejected because the AO relied on incorrect or double counted figures and ignored reconciliations and the assessee's percentage of completion accounting; the appellate authority's acceptance of reconciliations led to deletion of the addition. Both revenue grounds were dismissed.
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