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 ITAT held that leave encashment of ₹6.97 lakh was fully exempt as it fell within the revised ₹25 lakh ceiling under Notifi...
Income Tax : The ITAT allowed exemption of the entire leave encashment amount after noting that the revised ₹25 lakh ceiling exceeded the amo...
Income Tax : ITAT Hyderabad held that assessment orders passed pursuant to earlier remand directions were barred by limitation under Section 15...
Income Tax : The Bombay High Court held that reassessment proceedings became time-barred because no reassessment order was passed within the li...
Income Tax : The ITAT Kolkata held that delayed filing of Form No. 67 is only a procedural defect and cannot deprive an assessee of Foreign Tax...
The ITAT held that leave encashment of ₹6.97 lakh was fully exempt as it fell within the revised ₹25 lakh ceiling under Notification No. 31/2023. The appeal was allowed accordingly.
The ITAT allowed exemption of the entire leave encashment amount after noting that the revised ₹25 lakh ceiling exceeded the amount received on retirement. The appeal was allowed by applying the enhanced exemption limit.
ITAT Hyderabad held that assessment orders passed pursuant to earlier remand directions were barred by limitation under Section 153. The Tribunal set aside all consequential transfer pricing assessment orders dated 06.12.2024.
The Bombay High Court held that reassessment proceedings became time-barred because no reassessment order was passed within the limitation period prescribed under Section 153. The Court ruled that procedural remand directions did not extend limitation under Section 153(6).
The ITAT Kolkata held that delayed filing of Form No. 67 is only a procedural defect and cannot deprive an assessee of Foreign Tax Credit under Section 90 and the India-USA DTAA.
Court held that penalty under Section 270A cannot apply where assessed income does not exceed processed income. Key takeaway: statutory conditions must be strictly met.
ITAT Chennai set aside the appellate order and remanded issues on protective addition, Section 54F exemption, and TDS credit mismatch for fresh adjudication.
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.
