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Checkmate Services Pvt. Ltd.,, ... vs The Addl. Cit, Range-1,, Baroda on 31 January, 2023

5. In ground No. 3 the assessee claimed that the adjustment made by the CPC, Bengaluru is outside the purview of section 143(1)(a) of the Act and without being prejudiced to this if the amounts paid before the due dates as per EPF & MP Act, 1952 could not be disallowed. On this, in our considered view CPC, Bengaluru is well within its power while exercising powers u/s. 143(1)(a) of the Act, especially considering the scenario after the decision of the Hon'ble Apex Court in the case of [2022] 143 taxmann.com 178 (SC) Checkmate Services Pvt. Ltd. v. CIT-1. As far as an alternative plea is concerned, that again requires a detailed verification, concerning relevant records and challans etc. It will not be appropriate for us to decide the matter based on partial information, hence the same is restored to the Jurisdictional AO for verification after providing the assessee a reasonable opportunity of being heard and the assessee is directed to produce relevant ledgers along with audited accounts and relevant challans for verification before the Jurisdictional AO. In the above terms, Ground No. 3 raised by the assessee is allowed for statistical purposes.
Income Tax Appellate Tribunal - Ahmedabad Cites 19 - Cited by 323 - Full Document
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