Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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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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