Income Tax Assessing Officer Vs Shobhan Shantilal Doshi (Supreme Court of India)
The matter before the Supreme Court of India arose from an appeal filed by the Income Tax Department challenging only a limited portion of the judgment delivered by the Gujarat High Court. The appeal was expressly confined to examining the directions issued by the High Court in paragraphs 10 and 11 of its order, which required the Central Board of Direct Taxes (CBDT) to make changes in the income-tax software system. Importantly, the Department did not challenge the substantive relief granted to the assessee on merits.
Read HC Judgment in this case: Gayatri Snehal Rao Vs Income Tax Assessing Officer & Ors. (Gujarat High Court)
Before the High Court, the assessees, who were ex-employees of Karvy Stock Broking Limited, had challenged intimations issued under Section 143(1) of the Income-tax Act, 1961 for Assessment Years 2020–21 and 2021–22. These intimations were treated as notices of demand under Section 156, on account of a mismatch between Tax Deducted at Source (TDS) claimed by the assessees and TDS actually deposited by the employer. It was undisputed that while tax had been deducted from the assessees’ salary, the employer had failed to deposit the deducted amount with the Government.
