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...
Admissibility of additional evidence submitted during remand reconciled GSTR 1 entries with profit and loss turnover, leading to deletion of a turnover discrepancy addition because the Assessing Officer's remand report attributed the variance to earlier years. Recognition of interest on service concession receivable and deferred retention liability in the profit and loss account was treated as notional income recorded to comply with accounting standards (IND AS) and not taxable as actual income in the relevant year; the Tribunal sustained deletion of the section 56 addition, noting subsequent assessments accepted actual annuity interest treatment. Revenue appeal dismissed on both points.
Admissibility of additional evidence submitted during remand reconciled GSTR 1 entries with profit and loss turnover, leading to deletion of a turnover discrepancy addition because the Assessing Officer's remand report attributed the variance to earlier years. Recognition of interest on service concession receivable and deferred retention liability in the profit and loss account was treated as notional income recorded to comply with accounting standards (IND AS) and not taxable as actual income in the relevant year; the Tribunal sustained deletion of the section 56 addition, noting subsequent assessments accepted actual annuity interest treatment. Revenue appeal dismissed on both points.
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