The company contended that the satisfaction note required to initiate the assessment under section 153C was recorded by AO only on January 18, 2021, making the search year AY 2021-22.
In response to the notice under Section 263, assessee argued that the issue had already been examined during reassessment proceedings and that the AO had taken a plausible legal view.
The blocking and unblocking of ITC by the SGST authorities between 20.03.2021 and 07.07.2021 were not subject matter of any litigation where the issue of legality or correctness of such blocking was determined.
As per the said Statement of Accounts, there was an outstanding amount of Rs 1,85,25,373/- (Rupees One Crore Eighty-Five Lakh Twenty-Five Thousand Three Hundred and Seventy-Three only) which was due and payable by the Corporate Debtor as on 31.03.2024.
In the event and income sourced in India was not characterized under the heads provided in the DTAA, the income would be taxable under the residual clause provided taxing right was allocated to source country in this case to India under the relevant DTAA.
Assessee’s petition against the under declaration of ineligible Input Tax Credit ( ITC ) would be heard when assessee would deposit 10% of the disputed tax within a period of four weeks from the date of receipt of a copy of this order.
Denial of the entire expenditure incurred towards as cost of construction by AO could not be held to be justified even if assessee did not submit satisfactory bills/vouchers in support of her claim towards the cost of construction.
Hire charges of a vessel did not constitute ‘Royalty’ as it was in the nature of business income and as there was no Permanent Establishment therefore, no taxability arose on account of business income.
Assessee was a medical professional, filed his returns for the Assessment Year (AY) 2018-19. The appeal concerned an addition of over Rs. 179 crore made by AO under section 68 alleging unexplained cash credits in the assessee’s hands.
Entire cash deposits made during demonetization could not be treated as unexplained credit and a reasonable addition of 20% of total cash deposit would be sufficient to avoid the possibility of revenue leakage.
