Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Section 40(a)(ia) disallowance applies only to expenditure actually claimed as a deduction in computing business income; where TDS-defaulted amounts remained capitalised in work-in-progress and were not charged to the profit and loss account, no current-year disallowance was warranted. Even under the percentage completion method, the decisive question was whether the expense had entered the year's computation, and the balance had to be adjusted in work-in-progress to avoid later deduction without compliance. The audit report could not override the actual accounting treatment. The Tribunal therefore upheld the CIT(A)'s limited verification approach and dismissed the Revenue's appeal.
Section 40(a)(ia) disallowance applies only to expenditure actually claimed as a deduction in computing business income; where TDS-defaulted amounts remained capitalised in work-in-progress and were not charged to the profit and loss account, no current-year disallowance was warranted. Even under the percentage completion method, the decisive question was whether the expense had entered the year's computation, and the balance had to be adjusted in work-in-progress to avoid later deduction without compliance. The audit report could not override the actual accounting treatment. The Tribunal therefore upheld the CIT(A)'s limited verification approach and dismissed the Revenue's appeal.
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TaxTMI 
TaxTMI 
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