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2009 (8) TMI 12 - HC - Income TaxTDS Amount of TDS - Reopening of an assessement on the basis of difference in TDS certificate and amount shown in Profit and Loss Account - In respect of the assessment years 1996-97 to 2002-03 the assessing officer noted that there was a difference between the income as per the TDS certificate and that credited in the profit and loss account. The assessee's explanation was that in this line of business, tax is deducted on the gross income including reimbursable expenses incurred by the assessee. The explanation was not accepted by the assessing officer and he made an addition of the difference between the income as per the TDS and that credited in the profit and loss account CIT (A) accepted the contention of assessee ITAT remitted the matter by directing the assessee to explain and prove by way of proper reconciliation and documentary evidence the reason for the discrepancy further ITAT held that difference in TDS certificate and profit and loss account is sufficient ground to issue notice under section 148 order of ITAT upheld
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