complexity

Sustainability of orders passed by Settlement Commission in violation of section 245D(4) of IT Act, 1961

Chapter XIX-A is a complete Code in itself as regards settlement of cases for having provided a complete mechanism other than procedure provided under the IT Act. Legislature conferred all powers upon Settlement Commission being vested in IT authority under the Act as provided U/s 245-F and what is being decided by settlement commission is conclusive providing no remedy of revision/review or appeal to the assessee or revenue, envisaged in S.245-I of the Act.
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Power of AO to extend period for completion of special audit u/s 142(2A) of IT Act, 1961

The power to suo motu extend the period for completion of the special audit was available to the AO only w.e.f. 1-4-2008 and before such date, the extension can be made only at the request of the assessee on an application made in this behalf by the assessee.
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