The new law restructures TDS provisions into Sections 392, 393, and 394, altering compliance procedures. Correct selection of codes and deductee details is crucial to avoid errors and notices.
The court held that Sections 73 and 74 allow show cause notices for any period, not limited to a financial year. Consolidated notices are valid, subject to limitation checks for each period.
Dealer incentives like tour packages are taxable as business income under the new law. If TDS is borne by the payer, it must be added as additional income through grossing up.
The issue was rejection of a declaration under the dispute resolution scheme citing lack of quantification. The Court held that liability was quantified before the cutoff date and directed acceptance of the declaration.
The issue was deletion of additions on unsecured loans treated as unexplained cash credits. The tribunal upheld deletion, holding that a favourable remand report confirming genuineness and creditworthiness weakens the Revenue’s case.
The issue was cancellation of GST registration due to non-filing of returns and rejection of appeal as time-barred. The Court allowed manual filing of revocation application, emphasizing opportunity for compliance despite delay.
The new law defines strict conditions for reopening assessments using specified information categories. It ensures transparency and limits arbitrary reassessment powers.
The issue concerns fragmented litigation under the earlier tax regime. The new law integrates multiple proceedings into a unified process, reducing duplication. The key takeaway is that litigation is streamlined rather than eliminated.
The court held that a show cause notice lacking clear reasons and supporting documents violates natural justice. It quashed the retrospective cancellation, allowing fresh proceedings as per law.
The authority held that an automated locker system is classifiable under CTH 8303 as its essential function is secure storage of valuables. The ruling clarifies that automation features do not override the primary character of lockers.
