Consultancy fees claimed as business expense-can tax disallowance rest on survey suspicion despite invoices, contracts and bank trail? Appeal dismisse...
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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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