The Court ruled that Explanation 1 to Section 153A requires inclusion of the search assessment year while calculating the extended ten-year reassessment period.
The High Court distinguished contracts of other government departments that contained clauses for reimbursement of new taxes and held that no such parity could be claimed in the present case.
The High Court held that adjustment of refunds beyond 20% of disputed tax demand during pendency of appeal was unsustainable without proper justification. It directed refund of the excess amount adjusted under Section 245 of the Income Tax Act.
The Andhra Pradesh High Court held that ITC claims for FY 2019-20 filed in October 2020 were valid because Section 16(5) extended the filing deadline up to 30.11.2021.
ITAT Indore set aside the appellate order denying TDS credit after the assessee produced Form 16A and Form 26AS showing deduction and payment of tax by the deductor. The matter was remanded to the Assessing Officer for verification and grant of eligible credit.
The ITAT Ahmedabad held that a demolished and uninhabitable structure could not be treated as a residential house for Section 54F purposes. The Tribunal upheld the assessee’s eligibility for capital gains exemption.
The ITAT Mumbai ruled that income earned by a securitisation trust created under the SARFAESI Act was taxable in the hands of Security Receipt holders because the trust qualified as a revocable trust under Sections 61 to 63 of the Income Tax Act.
The ITAT Indore held that Section 50C could not be invoked where the difference between actual sale consideration and stamp duty valuation was only 1.19%. The Tribunal directed adoption of actual sale consideration as the full value for capital gains computation.
The ITAT Ahmedabad held that Form 10-IE filed along with the return could not be ignored merely because it was not filed within the due date under Section 139(1). The Tribunal directed CPC to recompute tax under the new tax regime.
ITAT Hyderabad held that deduction under Section 80JJAA cannot be denied merely because Form No. 10DA was filed late due to technical glitches on the income tax portal. The Tribunal noted that the form was available with CPC before processing the return.
