On appeal. It was held that application for refund was rightly rejected, as it was filed beyond the prescribed limitation period of six years from the end of the assessment year for which the application/claim was made.
Assessee had received Rs. 13.36 crores by cheque/RTGS out of total cash deposit of Rs.24.35 crores in bank account of M/s R. S. Traders during demonetization period. During the survey, several documents and evidences were collected and impounded.
A similar claim for deduction as was raised by assessee-firm in the preceding year had been allowed by the department, but also the fact that the GP/NP rates of assessee firm were progressive as in comparison to the preceding year.
It was a case where the statutory procedure mandated in section 144C had been attempted to be by passed by merely mentioning the name of the assessee as the amalgamated entity with its former name and the name of amalgamating company.
The invitation card for the marriage ceremony in Guru vaguer was also placed on record as Annexure P-3. Assessee was said to have been wearing a gold chain weighing 32 gms which was detained by the Department.
Penalty imposed under section 271(1)(b) for non-compliance with a notice during the Covid-19 pandemic was deleted due to disruptions caused by lockdowns during outbreak of Covid-19 Pandemic and the Supreme Court’s extension of limitation periods.
Since CIT(Appeals) dismissed the appeal without addressing key issues raised against the assessment order, therefore, the matter was remanded back to CIT(A) as CIT(A) should have examined this issue by reviewing the assessment records.
Addition based on the District Valuation Officer’s (DVO) report, which exceeded the stamp duty value was upheld as assessee challenged to DVO’s valuation was arbitrary without any supporting evidence.
Assessee claimed deduction of IMC Transfer Expenses, City Environment Expenses, Contribution and Aid Expenses, Land Acquisition and Diversion Expenses which the AO disallowed the same.
According to AO, the provisions were not allowable who vide show cause notice asked assessee to furnish details of the provisions made as well as justification for the claim and the assessee did not file any reply to the show cause notice issued.
