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Tax Publishers
Shakti Malt (P) Ltd. v. ITO [ITA No. 172/Jp/2019,
dt. 13-10-2020] : 2020 TaxPub(DT) 4248 (Jp.-Trib.)
Rectification of order route used for sustaining additions
post scrutiny assessment -- Validity
Facts:
Assessee was subject to a scrutiny assessment where certain
interest was allowed. Subsequently arising out of an audit objection the
assessing officer proposed to disallow certain interest citing these were not
used for the purpose of business by invoking rectification route under section
154. The same was upheld by Commissioner (Appeals). On higher appeal -
Held in favour of the assessee that debatable issue of
interest allowability that too after a scrutiny assessment cannot be disallowed
using rectification route under section 154.
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