S. 234B: Interest-Advance tax-Non-Resident-Deduction at source-Interest not leviable. [S. 195]
S. 234B: Interest-Advance tax-Non-Resident-Deduction at source-Interest not leviable. [S. 195]
S. 199: Deduction at source-Credit for tax deducted-Trust-Trustee-TDS in the name of Trustee-Assessing Officer was to be directed to give due credit to assessee-trust if credit of TDS was in name of trustee and details were given whether money was credited by trustee into account of trust. [S. 143(1), 154]
S. 154: Rectification of mistake-Mistake apparent from the record-Enhance assessment or reduce refund-Order passed without giving an opportunity of hearing-Rectification order was set aside. [S. 143(3), 154(3)]
S. 154: Rectification of mistake-Mistake apparent from the record-Investment in mutual fund-Name of assessee as second holder-Order was passed without giving an opportunity of hearing-Rectification order was set aside. [S. 143(3)]
S. 153B : Assessment-Time limit-Exchange information-Reference was on 14-11-2012-Article 26 ceased to exist after 30-8-2010-Period of limitation could not be extended under Explanation (ix) to section 153B to frame assessment based on such reference-Assessment order was quashed and set aside on ground of limitation-DTAA-India-Swiss [S. 90, 90A, 153B(ix) Art.24, 26]
S. 149: Reassessment-Time limit for notice-For assessment year 2015-16, notice under section 148 issued on 29-7-2022 was beyond the limitation period prescribed under section 149 and was barred by limitation.[S. 68, 148, 148A(b), 148A(d)]
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Beyond three years-Income alleged escapement was less than 50 lakhs, i.e., 32.78 lakhs-Reassessment notice and consequential assessment orders were void ab initio, hence quashed. [S. 56 (2) (vii)(b), 147, 148, 148A(b), 148A(d), 149(1)(b)]
S. 147 : Reassessment-Cash credits-Accommodation entries-Share capital-Failure to comply with filing with ROC-Huge share capital in balance sheet-Reassessment proceedings were quashed and set aside.[S. 68, 148]
S. 147: Reassessment-Unexplained investment-Information from Insight portal-Objection was not disposed of-Reassessment order was quashed and set aside. [S.69, 148]
S 144: Best judgment assessment-Amounts of investments not fully disclosed in books of account-Purchase of flat-Investment from maturity of fixed deposits-Matter was restored to the file of the Assessing Officer for a fresh examination. [S.69B]