Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
ITAT held that the plea of denial of opportunity in assessment was factually untenable because statutory notices were issued, replies were filed, and the assessee had not raised the grievance before the first appellate authority. It further held that the dispute concerned only the year of taxability of contractual receipts, which depended on the accounting method actually followed. As the assessee failed to substantiate the claimed completed service contract method, had received the amounts in the relevant year, and the receipts were reflected in Form 26AS with tax deduction, the additions were sustained and the receipts were taxable in Assessment Year 2018-19.
ITAT held that the plea of denial of opportunity in assessment was factually untenable because statutory notices were issued, replies were filed, and the assessee had not raised the grievance before the first appellate authority. It further held that the dispute concerned only the year of taxability of contractual receipts, which depended on the accounting method actually followed. As the assessee failed to substantiate the claimed completed service contract method, had received the amounts in the relevant year, and the receipts were reflected in Form 26AS with tax deduction, the additions were sustained and the receipts were taxable in Assessment Year 2018-19.
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