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...
Section 201(3) limitation begins from the end of the financial year in which each quarterly TDS statement is filed, making each quarterly filing an independent trigger for the two-year limitation period; Rule 31A's quarterly filing requirement confirms that each quarter is a distinct compliance event and precludes an annual or cumulative computation of limitation. The statutory language and TDS scheme require strict construction of limitation, so earlier quarters filed in one financial year are time-barred while a quarter filed in the subsequent financial year remains within limitation; the Tribunal's conclusion dismissing the appeal as to limitation was affirmed.
Section 201(3) limitation begins from the end of the financial year in which each quarterly TDS statement is filed, making each quarterly filing an independent trigger for the two-year limitation period; Rule 31A's quarterly filing requirement confirms that each quarter is a distinct compliance event and precludes an annual or cumulative computation of limitation. The statutory language and TDS scheme require strict construction of limitation, so earlier quarters filed in one financial year are time-barred while a quarter filed in the subsequent financial year remains within limitation; the Tribunal's conclusion dismissing the appeal as to limitation was affirmed.
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