Income Tax : An overview of Section 144 of the Indian Income Tax Act, which allows an Assessing Officer to make a best judgment assessment in c...
Income Tax : An analysis of Sections 263 and 264 of the Income-tax Act, 1961. It details the conditions, scope, and judicial precedents for the...
Income Tax : The High Court held that once a resolution plan under IBC extinguishes prior tax liabilities, reassessment cannot be initiated. Th...
Income Tax : The Tribunal held that delay in filing Form 67 is a procedural lapse. It restored the matter to the AO to verify and allow Foreign...
Income Tax : The tribunal examined whether penalties could continue when the fresh assessment order did not record satisfaction for initiating ...
Income Tax : The Tribunal accepted that the deposits represented funds withdrawn earlier for house construction. Since the explanation was supp...
Income Tax : The Tribunal held that where the AO had examined and accepted exemption on interest under Section 28 of the Land Acquisition Act, ...
The High Court held that once a resolution plan under IBC extinguishes prior tax liabilities, reassessment cannot be initiated. The notice under Section 148 was set aside. The ruling confirms that extinguished claims cannot be revived through reassessment.
The Tribunal held that delay in filing Form 67 is a procedural lapse. It restored the matter to the AO to verify and allow Foreign Tax Credit if eligible.
The tribunal examined whether penalties could continue when the fresh assessment order did not record satisfaction for initiating them. It ruled that absence of such satisfaction makes the penalties invalid in law.
The Tribunal accepted that the deposits represented funds withdrawn earlier for house construction. Since the explanation was supported by loan records and confirmations, the addition was removed.
The Tribunal held that where the AO had examined and accepted exemption on interest under Section 28 of the Land Acquisition Act, revision under Section 263 was not justified.
The Delhi High Court held that delay in filing Form No. 67 cannot defeat a substantive claim for Foreign Tax Credit. It directed the Assessing Officer to verify and grant FTC, observing that denial on technical grounds would amount to unjust enrichment.
The Court held that failure to comply with payment conditions under the 2020 Scheme automatically revived withdrawn revision petitions. This made the assessee eligible under the 2024 DTVSV Scheme.
The Supreme Court refused to interfere with the High Court’s decision dismissing a revision filed after nearly seven years. It affirmed that unexplained and excessive delay defeats relief under Section 264.
The High Court upheld rejection of a belated revision filed nearly seven years after rectification denial. It ruled that no sufficient cause was shown to condone the inordinate delay.
The court examined whether withholding tax could be imposed solely on the basis of an alleged virtual service permanent establishment. It ruled that such a concept is not recognised under the DTAA and remanded the matter for fresh consideration.
