Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Omission to claim deductions and exemptions in an earlier rectification request was not treated as fatal where the tax position was otherwise supported by Form 16 and Form 26AS. The ITAT applied the principle that tax cannot be collected without authority of law and that the Revenue cannot gain from an assessee's ignorance. As the records reflected TDS and advance tax payments, the assessee was given a further opportunity to produce supporting documents. The matter was remitted to the Assessing Officer for de novo assessment and fresh consideration of the claimed deductions, exemptions and tax credits.
Omission to claim deductions and exemptions in an earlier rectification request was not treated as fatal where the tax position was otherwise supported by Form 16 and Form 26AS. The ITAT applied the principle that tax cannot be collected without authority of law and that the Revenue cannot gain from an assessee's ignorance. As the records reflected TDS and advance tax payments, the assessee was given a further opportunity to produce supporting documents. The matter was remitted to the Assessing Officer for de novo assessment and fresh consideration of the claimed deductions, exemptions and tax credits.
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