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Pune Branch of WIRC of
the ICAI
Pune Branch of WIRC of
the ICAI
Issues relating to TDS compliance with
special reference to special reference to SECTION 234 E
CA Chandrashekhar V. Chitale
Issues relating to TDS compliance with
special reference to special reference to SECTION 234 E
CA Chandrashekhar V. Chitale
Issues relating to TDS
compliance
Issues relating to TDS
compliance
Application for No TDS
• Section 197
• No TDS or Lower TDS
• Application in Form No. 13• Application in Form No. 13
• Can it be made before commencement
of Financial Year?
• Approval?
Application for No TDS
No TDS or Lower TDS
Application in Form No. 13Application in Form No. 13
Can it be made before commencement
Application for No TDS
• The assessee was entitled to file an
application for a certificate of deduction
at a lower rate even before the at a lower rate even before the
commencement of the financial year in
which that tax is to be deducted.
Indus Towers Ltd. v. ACIT (TDS)
(2014) 220 Taxmann 402 (Delhi)(HC)
Application for No TDS
The assessee was entitled to file an
application for a certificate of deduction
at a lower rate even before the at a lower rate even before the
commencement of the financial year in
which that tax is to be deducted.
Indus Towers Ltd. v. ACIT (TDS)
(2014) 220 Taxmann 402 (Delhi)(HC)
Application for No TDS
• 28AA. (1) The Assessing Officer, on an
application made by a person under sub
(1) of rule 28, may issue a certificate in (1) of rule 28, may issue a certificate in
accordance with the provisions of sub
(1) of section 197 for deduction of tax at
source at the rate or rates calculated in the
manner specified below :
Application for No TDS
(1) The Assessing Officer, on an
application made by a person under sub-rule
(1) of rule 28, may issue a certificate in (1) of rule 28, may issue a certificate in
accordance with the provisions of sub-section
(1) of section 197 for deduction of tax at
source at the rate or rates calculated in the
manner specified below :
…….. Contd.
Application for No TDS
• 28AA. (1)
• (i) at such average rate of tax as determined
by the total tax payableby the total tax payable
as reduced by the sum of advance tax
already paid and tax already deducted at
source, as a percentage of the payment
referred to in section 197 for which the
application under sub-
been made; or
Application for No TDS
at such average rate of tax as determined
ble on estimated income, ble on estimated income,
as reduced by the sum of advance tax
already paid and tax already deducted at
source, as a percentage of the payment
referred to in section 197 for which the
rule (1) of rule 28 has
Application for No TDS
• 28AA. (1)
• (ii) at the average of the average rates of tax
paid by the assessee in the last three years;paid by the assessee in the last three years;
• whichever is higher.
Application for No TDS
at the average of the average rates of tax
paid by the assessee in the last three years;paid by the assessee in the last three years;
Interest S. 201
• S.195 : TDS Failure
• If no income arose to recipient then notices to payer for TDS default u/s. notices to payer for TDS default u/s. 201 & disallowance under section 40(a)(ia)are bad
• Samsung India Electronics Pvt. Ltd. v.
DDIT (Delhi) (HC). www.itatonline.org
Interest S. 201
S.195 : TDS Failure
If no income arose to recipient then notices to payer for TDS default u/s. notices to payer for TDS default u/s. 201 & disallowance under section
Samsung India Electronics Pvt. Ltd. v.
DDIT (Delhi) (HC). www.itatonline.org
Interest S. 201
• Order cannot be passed after 4 years
have elapsed
• Time limit is counted from the • Time limit is counted from the
assessment year and not from he date
of survey
• STATE BANK OF INDIA vs. ACIT
• (2007) 106 ITD 589 (Mumbai)
Interest S. 201
Order cannot be passed after 4 years
Time limit is counted from the Time limit is counted from the
assessment year and not from he date
STATE BANK OF INDIA vs. ACIT
(2007) 106 ITD 589 (Mumbai)
Interest S. 201
• Valuation of perquisite
• Standard rent charged without exception
• No perquisite considered• No perquisite considered
• The employer is expected to act
honestly and fairly. Unless any inference
can be drawn that the employer did not
act honestly and fairly, it cannot be said
that he has not deducted proper tax
Interest S. 201
Valuation of perquisite – furniture
Standard rent charged without exception
No perquisite consideredNo perquisite considered
The employer is expected to act
honestly and fairly. Unless any inference
can be drawn that the employer did not
act honestly and fairly, it cannot be said
that he has not deducted proper tax.
Interest S. 201
• Require - a broad picture of estimated
income, which is subjected to tax. The
Department must show on record, that Department must show on record, that
non-deduction of tax at source was mala
fide on the part of the employer.
• Therefore, no interest charged u/s 201
• STATE BANK OF INDIA vs. ACIT
• (2007) 106 ITD 589 (Mumbai)
Interest S. 201
a broad picture of estimated
income, which is subjected to tax. The
Department must show on record, that Department must show on record, that
deduction of tax at source was mala
fide on the part of the employer.
Therefore, no interest charged u/s 201
STATE BANK OF INDIA vs. ACIT
(2007) 106 ITD 589 (Mumbai)
Interest S. 201
• Where action of assessee for not
deducting tax at source on conveyance
allowance paid to employees was based
on bona fide belief, assessee on bona fide belief, assessee
be treated as assessee in default liable
to interest under section 201(1A)
• CIT v. I.T.C. Ltd.
• (2013) 263 CTR 241 (All.)(HC)
Interest S. 201
Where action of assessee for not
deducting tax at source on conveyance
allowance paid to employees was based
on bona fide belief, assessee could noton bona fide belief, assessee could not
be treated as assessee in default liable
to interest under section 201(1A)
(2013) 263 CTR 241 (All.)(HC)
Interest S. 201
• Deduction under ss. 80G and 80GGA not admissible u/s. 192
• AO justified in charging s. 201 int.• AO justified in charging s. 201 int.
• Evidence of filing of returns by the employees and payment taxes
• AO shall reduce int. u/s. 201
• MAHENDRA TEC. INTER COLLEGE115 ITD 411 (All)
Interest S. 201
Deduction under ss. 80G and 80GGA not admissible u/s. 192
AO justified in charging s. 201 int.AO justified in charging s. 201 int.
Evidence of filing of returns by the employees and payment taxes
AO shall reduce int. u/s. 201
MAHENDRA TEC. INTER COLLEGE
Interest S. 192
• S 192 – No proof for LTA
• Assessee held in default
• L&T 221 CTR 620 (SC)
• Annual Salary TDS Circular
• Also for, Medical Exp. Reimbursement
Interest S. 192
No proof for LTA
Assessee held in default
(SC)
Annual Salary TDS Circular
Also for, Medical Exp. Reimbursement
Interest S. 192
• S 192 – Deduct tax at average rate
• No Deduction Uniformly
• S 193(3)• S 193(3)
• VINSONS 89 ITD 267 (Mum)
• Grasim Industries 92 TTJ 944
Interest S. 192
Deduct tax at average rate
No Deduction Uniformly – Interest?
89 ITD 267 (Mum)
Grasim Industries 92 TTJ 944
Interest S. 192
• Is employer responsible for misuse of lunch coupons?
• Reliance Industries Ltd.
• 308 ITR 82 (Guj)
Interest S. 192
Is employer responsible for misuse of lunch coupons?
Reliance Industries Ltd.
Interest S. 192
• A receives salary from XYZ Ltd.
• A also receives salary from PQR
• Is XYZ Ltd. liable for shortfall of TDS • Is XYZ Ltd. liable for shortfall of TDS for not considering PQR salary?
• Woodward Governor India Pvt. Ltd.
• 295ITR 1 (Del)
Interest S. 192
A receives salary from XYZ Ltd.
A also receives salary from PQR
Is XYZ Ltd. liable for shortfall of TDS Is XYZ Ltd. liable for shortfall of TDS for not considering PQR salary?
Woodward Governor India Pvt. Ltd.
Interest S. 194A
• Do discounting charges fall under the definition of “interest”?
• DCIT v. Cargill Global Trading (I) (P) Limited [2009] 34 SOT 424
Interest S. 194A
Do discounting charges fall under the definition of “interest”?
DCIT v. Cargill Global Trading (I) (P) Limited [2009] 34 SOT 424
Interest S. 194A
• Discounting charges of bills of exchange –is not in the nature of interest for purposes of TDS u/s 194A interest for purposes of TDS u/s 194A or disallowance u/s 40(a)(ia)
• ITO v. M K J Enterprises Ltd.
(Kol.)(Trib.) www. itatonline.org
Interest S. 194A
Discounting charges of bills of is not in the nature of
interest for purposes of TDS u/s 194A interest for purposes of TDS u/s 194A or disallowance u/s 40(a)(ia)
ITO v. M K J Enterprises Ltd.
(Kol.)(Trib.) www. itatonline.org
Interest S. 194C v. 194I
• Fixed vehicle charges for transportation of employees
• AO – 194 I - Cir. 715 dated 8• AO – 194 I - Cir. 715 dated 8
• Judgment – 194C -
passengers by any mode of transport
• Ahmedabad Urban Development Authority v ACIT (10 taxmann.com 233) (Ahmbd Trib)
Interest S. 194C v. 194I
Fixed vehicle charges for transportation of employees
Cir. 715 dated 8-8-1995Cir. 715 dated 8-8-1995
Carriage of goods passengers by any mode of transport
Ahmedabad Urban Development Authority v ACIT (10 taxmann.com
Interest S. 194H
• Can discount on supply of SIM cards and recharge coupons be termed as “commission”?
• No Sale of Goods
• Vodafone Essar Cellular Limited
• (332 ITR 255)
Interest S. 194H
Can discount on supply of SIM cards and recharge coupons be termed as
Vodafone Essar Cellular Limited
Interest S. 194H
• Product Discount Scheme
• TDS does not apply to all sales promotional expenditure. promotional expenditure.
• Applies if principal & agent relations
• Sale of Goods
• CIT v. Intervet India Pvt. Ltd.
(Bom.)(HC); www. itatonline.org • Also, CIT v. Mother Dairy India Ltd. (2013) 358 ITR 218 (Delhi)
Interest S. 194H
Product Discount Scheme –
TDS does not apply to all sales promotional expenditure. promotional expenditure.
Applies if principal & agent relations
CIT v. Intervet India Pvt. Ltd.
(Bom.)(HC); www. itatonline.org CIT v. Mother Dairy India Ltd. (2013) 358 ITR 218 (Delhi)
Interest S. 194I
• Infrastructure claims paid to franchisees vs. ‘Rent’ u/s 194I
• CIT vs. NIIT Ltd.
• (184 Taxman 472) (Del.)
Interest S. 194I
Infrastructure claims paid to franchisees vs. ‘Rent’ u/s 194I
(184 Taxman 472) (Del.)
26 AS TDS Mismatch
• TDS allowed in the year of income reporting
• CPC allows credit based on Form No 26AS
• No specific guidance to resolve mismatch• No specific guidance to resolve mismatch
• Approach jurisdiction AO to resolve
• He usually sends ball to the CPC
26 AS TDS Mismatch
TDS allowed in the year of income reporting
CPC allows credit based on Form No 26AS
No specific guidance to resolve mismatchNo specific guidance to resolve mismatch
Approach jurisdiction AO to resolve
He usually sends ball to the CPC
26 AS TDS Mismatch
• Instruction No. 5/2013 F.No.275/03/2013IT(B), dated 8.07.2013
• The CBDT instructions for processing of • The CBDT instructions for processing of Income-tax returns and giving credit for TDS thereon in the case of TDS mismatch
• Based on Court On its Own Motion v. UOI and Ors. (W.P. (C) 2659/2012 & W.P. (C) 5443/2012 dated 14-3
26 AS TDS Mismatch
Instruction No. 5/2013 F.No.275/03/2013-IT(B), dated 8.07.2013
The CBDT instructions for processing of The CBDT instructions for processing of tax returns and giving credit for TDS
thereon in the case of TDS mismatch
Court On its Own Motion v. UOI . (W.P. (C) 2659/2012 & W.P. (C)
3-2013)
26 AS TDS Mismatch
• When assessee approaches AO with
requisite details and particulars in the form
of TDS certificate agaof TDS certificate aga
said AO will verify whether or not the
deductor has made payment of the TDS in
the Government Acco
has been made, credit of the same should
be given to the assessee.
26 AS TDS Mismatch
When assessee approaches AO with
requisite details and particulars in the form
gainst any mismatch, the gainst any mismatch, the
said AO will verify whether or not the
deductor has made payment of the TDS in
count and if the payment
has been made, credit of the same should
be given to the assessee.
26 AS TDS Mismatch
• The AO may also, if deemed necessary,
issue a notice to the deductor to compel
him to file correction statement as per him to file correction statement as per
the procedure laid down
26 AS TDS Mismatch
The AO may also, if deemed necessary,
issue a notice to the deductor to compel
him to file correction statement as per him to file correction statement as per
the procedure laid down
26 AS TDS Mismatch
• Citicorp Finance (India) Ltd vs. ACIT (ITAT Mumbai)
• TDS mismatch with Form No. 26AS• TDS mismatch with Form No. 26AS
• Credit was denied by the AO
• Held: AO not justified in denying credit for TDS because the TDS is not reflected in the computer generated Form 26AS
26 AS TDS Mismatch
Citicorp Finance (India) Ltd vs. ACIT
TDS mismatch with Form No. 26ASTDS mismatch with Form No. 26AS
Credit was denied by the AO
Held: AO not justified in denying credit for TDS because the TDS is not reflected in the computer generated Form 26AS
26 AS TDS Mismatch
The AO is not justified in denying TDS credit on
the ground that the TDS is not reflected in the
computer generated Form 26AS.
In Yashpal Sahwney 293 ITR 539 (
noted the difficulty faced by taxpayers in getting
credit of TDS. Held : even if the deductor had not
issued a TDS certificate, still the claim of the
assessee has to be consid
evidence produced for deduction of tax at source
26 AS TDS Mismatch
The AO is not justified in denying TDS credit on
the ground that the TDS is not reflected in the
computer generated Form 26AS.
293 ITR 539 (Bom) has
noted the difficulty faced by taxpayers in getting
. Held : even if the deductor had not
issued a TDS certificate, still the claim of the
sidered on the basis of the
evidence produced for deduction of tax at source
No TDS
• Tax cannot be recovered from payer if already recovered from payee
• NO – S. 191• NO – S. 191
• However, interest u/s 201(1A) and penalty u/s 271C can be charged
• Interest u/s 201(1A) up to tax payment by the deductee
• Hindustan Coca-Cola Beverage P. Ltd. v CIT (293 ITR 226)
No TDS
Tax cannot be recovered from payer if already
However, interest u/s 201(1A) and penalty u/s
Interest u/s 201(1A) up to tax payment by the
Cola Beverage P. Ltd. v CIT
No TDS
• TDS obligation depends on law prevailing on date of payment and is not affected by retrospective amendmentretrospective amendment
• No disallowance u/s 40(a)(i) r.w.s. 9(1) (vii) if that law did not require TDS
• DCIT v. Virola International (Agra)(Trib.) www. itatonline.org
No TDS
TDS obligation depends on law prevailing on date of payment and is not affected by retrospective amendment-retrospective amendment-
No disallowance u/s 40(a)(i) r.w.s. 9(1) (vii) if that law did not require TDS
DCIT v. Virola International (Agra)(Trib.)
Interest on TDS Refund
• S.244A : Refunds – Interest source – Deductor entitled to interest on refund of excess TDS from date of refund of excess TDS from date of payment. [S. 156, 195, 240, 244]
• UOI v. Tata Chemicals Ltd.
• (2014) 267 CTR 89(SC)
Interest on TDS Refund
Interest – Deduction at Deductor entitled to interest on
refund of excess TDS from date of refund of excess TDS from date of payment. [S. 156, 195, 240, 244]
UOI v. Tata Chemicals Ltd.
(2014) 267 CTR 89(SC)
S. 199
• Credit for TDS given to person in whose hands income is assessable
• Since income is assessable in hands of AOP • Since income is assessable in hands of AOP credit for the TDS shall also be granted only to the AOP and cannot be granted to the assessee. (A.Y. 2008-
• ITO v. Amee Hosang Mistry
• (2014) 29 ITR 397 (Mum.)(Trib.)
S. 199
Credit for TDS given to person in whose hands income is assessable
Since income is assessable in hands of AOP Since income is assessable in hands of AOP credit for the TDS shall also be granted only to the AOP and cannot be granted to the
-09)
ITO v. Amee Hosang Mistry
(2014) 29 ITR 397 (Mum.)(Trib.)
Non Compliance
•
Non Compliance
•
Consequences of DefaultsConsequences of Defaults
Consequences of Defaults
• MSEB Case
• Recovery
• Levy of Fees• Levy of Fees
• Interest
• Penalty
• Prosecution
• Disallowance
Consequences of Defaults
MSEB Case
• Total TDS - Rs. 1,61,605
• TDS Made and Paid in Time
• TDS Certificates – Delay in Issuing• TDS Certificates – Delay in Issuing
• Penalty – Rs. 1,31,70,600
• Pune ITAT Exhonoutated
MSEB Case
Rs. 1,61,605
TDS Made and Paid in Time
Delay in IssuingDelay in Issuing
1,31,70,600
Pune ITAT Exhonoutated48 ITD 414 (Pune)
Levy of Fees
NEW PROVISION – SECTION 234E
For Delay / Failure to Deliver TDS / TCS For Delay / Failure to Deliver TDS / TCS
Statements
Fees Rs. 200 per day
To be paid before delivering Statement
Applicable from July 1, 2012
Levy of Fees
SECTION 234E
For Delay / Failure to Deliver TDS / TCS For Delay / Failure to Deliver TDS / TCS
To be paid before delivering Statement
Applicable from July 1, 2012
STATEMENTSSTATEMENTS
S. 200 (3)
(i) A Tax Deductor and
(ii) An employer
after paying TDS to Governmentafter paying TDS to Government
Prepare such statements for such
period as may be prescribed and
deliver to the prescribed income
authority or person authorised
S. 200 (3)
(i) A Tax Deductor and
after paying TDS to Governmentafter paying TDS to Government
Prepare such statements for such
period as may be prescribed and
deliver to the prescribed income-tax
authority or person authorised
S. 200 (3)
• The statement shall be in prescribed
(i) Form
• (ii) Verification• (ii) Verification
• (iii) Particulars
and
• (iv) Furnished within prescribed time
S. 200 (3)
The statement shall be in prescribed
and
(iv) Furnished within prescribed time
S. 206C (3)
Person collecting tax shall, after
paying the tax collected to the the
Central Government within the Central Government within the
prescribed time, prepare prescribed
statements for prescribed period
and deliver to prescribed income
authority or authorised person.
S. 206C (3)
Person collecting tax shall, after
paying the tax collected to the the
Central Government within the Central Government within the
prescribed time, prepare prescribed
statements for prescribed period
and deliver to prescribed income-tax
authority or authorised person.
S. 206C (3)
The statement shall be in prescribed:
(i) Form
(ii) Verification (ii) Verification
(iii) particulars
and
(iv) Furnish within prescribed time
S. 206C (3)
The statement shall be in prescribed:
Furnish within prescribed time
Form for Statements
• TDS:
• Salary – Form No. 24Q
• Non-resident – Form No. 27Q • Non-resident – Form No. 27Q
• Others – Form No. 26Q
• TCS – Form No. 27EQ
Form for Statements
Form No. 24Q
Form No. 27Q Form No. 27Q
Form No. 26Q
Form No. 27EQ
Time for Statements
• Due Dates for Quarterly Returns
Quarter Ending
April - June 2014
July - Sept 2014
Oct. - Dec 2014
Jan - March 2015
Time for Statements
Due Dates for Quarterly Returns
On or before
July 15, 2014
October 15, 2014
January 15, 2015
May 15, 2015
Rule 31A /31AA
Delay in Statements
The statements :
If furnished
or not furnished
Fees
Are payable
Delay in Statements
The statements :
If furnished belatedly
furnished
Fees
Are payable
S. 234 E
234E - Fee for defaults in statements
• Where a person fails to deliver a
statement within the time statement within the time
prescribed, he shall be liable to pay,
by way of fee of Rs. 200 per dayduring which failure to file
or (2) TCS statements
S. 234 E
Fee for defaults in statements
Where a person fails to deliver a
statement within the time statement within the time
prescribed, he shall be liable to pay,
Rs. 200 per dayduring which failure to file (1) TDS
or (2) TCS statements continues
S. 234 E
• The amount of fee shall
the amount of tax deductible or
collectible, as the case may becollectible, as the case may be
• Fee shall be paid before delivering
TDS (S. 200) or TCS (S 206C)
Statement
S. 234 E
The amount of fee shall not exceed the amount of tax deductible or
collectible, as the case may becollectible, as the case may be
Fee shall be paid before delivering
TDS (S. 200) or TCS (S 206C)
S. 234 E
• The Fees shall apply to a statement
for tax deducted at source or tax
collected at source, as the case collected at source, as the case
may be, on or after the 1st day of
July, 2012
S. 234 E
The Fees shall apply to a statement
for tax deducted at source or tax
collected at source, as the case collected at source, as the case
may be, on or after the 1st day of
NoticeNotice
Notice Notice - 1
Notice Notice - 2
Notice Notice - 3
Notice Notice - 4
Intimation
Under Section 200A
Intimation - 1
Under Section 200A
Intimation Intimation - 2
ACTION PLANACTION PLAN
ACTION PLAN
•Points for Defence
•Application for •Application for
Rectification
•Appeal
ACTION PLAN
Points for Defence
Application for Application for
Rectification
Points for Defence
•No time limit for TDS
Statement processing Statement processing
under section 200A
Points for Defence
No time limit for TDS
Statement processing Statement processing
under section 200A
Points for Defence
•Fees are charged for
rendering of servicesrendering of services
•What service is
rendered?
Points for Defence
Fees are charged for
rendering of servicesrendering of services
What service is
Saving Points
•Section 200A does not
cover ‘fees’ under cover ‘fees’ under
section 234E
Saving Points
Section 200A does not
cover ‘fees’ under cover ‘fees’ under
section 234E
Points for Defence
• Section 234E(3):
• Fees to be paid before • Fees to be paid before
delivering statement
• How can it be demanded
afterwards?
Points for Defence
Section 234E(3):
Fees to be paid before Fees to be paid before
delivering statement
How can it be demanded
Points for Defence
• No mechanism for recovery
of ‘fees’ under section 234Eof ‘fees’ under section 234E
• Who has authority to
recover?
Points for Defence
No mechanism for recovery
under section 234Eunder section 234E
Who has authority to
Points for Defence
• File statements ‘after’ TDS
payment within prescribed time
limit.limit.
• Where is requirement to file
statement if TDS is paid after
due date?
Points for Defence
File statements ‘after’ TDS
payment within prescribed time
Where is requirement to file
statement if TDS is paid after
Points for Defence
• Without payment of TDS,
statement cannot be filed.
• How to file TDS statement, • How to file TDS statement,
when payment is not made?
• How to perform impossible?
Points for Defence
Without payment of TDS,
statement cannot be filed.
How to file TDS statement, How to file TDS statement,
when payment is not made?
How to perform impossible?
Points for Defence
• File statements ‘after’ TDS is paid.
• Delay is served with interest
• How can there be double
punishment for same offence?
• Case of penalty for tax audit
where no accounts were kept
Points for Defence
File statements ‘after’ TDS is paid.
Delay is served with interest
How can there be double
punishment for same offence?
Case of penalty for tax audit –
where no accounts were kept
Points for Defence
Cir No. 07/2014 / F. No. 275/27/2013
• CBDT has received several petitions from Deductors /collectors regarding TDS/TCS statements due to late furnishing of the TDS/TCS statements due to late furnishing of the Book Identification Number
• Due date extend u/s 200(3) to 2012-13 and 2013-14. No fees applicable.
• Is it not discriminatory?
Points for Defence
F. No. 275/27/2013-IT(B)/4.3.14
CBDT has received several petitions from GOVT./collectors regarding delay in filing of
due to late furnishing of the due to late furnishing of the Book Identification Number
Due date extend u/s 200(3) to 31-3-2014 for F.Y. No fees applicable.
Is it not discriminatory?
ACTION PLAN
Stupid Question Has a Foolish Answer
ACTION PLAN
Stupid Question Has a Foolish Answer
ACTION PLAN
•Application for
RectificationRectification
•Appeal
ACTION PLAN
Application for
RectificationRectification
Application for Rectification
•Section 154
•Rectification of mistake •Rectification of mistake
apparent from record
Application for Rectification
Section 154
Rectification of mistake Rectification of mistake
apparent from record
Application for Rectification
• Within 4 years from the end
of F.Y. in which order is of F.Y. in which order is
passed
• To the officer making order
• Format?
Application for Rectification
Within 4 years from the end
of F.Y. in which order is of F.Y. in which order is
To the officer making order
Appeal
•Section 246A
•To CIT(A)•To CIT(A)
•Within 30 days of
receipt of order
Appeal
Section 246A
Within 30 days of
receipt of order
Appeal
•Form No. 35
•Appeal fees•Appeal fees
•Grounds of Appeal
•Statement of Facts
Appeal
Form No. 35
Appeal feesAppeal fees
Grounds of Appeal
Statement of Facts
Appeal
• Application for Rectification
&&
• Appeal
• Can be made simultaneously?
Appeal
Application for Rectification
&&
Can be made simultaneously?
Intermission
It was a C. V. Chitale & Co. presentation!
Intermission
It was a C. V. Chitale & Co. presentation!
