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The Tribunal accepted that the deposits represented funds withdrawn earlier for house construction.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The Court held that failure to comply with payment conditions under the 2020 Scheme automatically revived withdrawn revision petitions.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.
The Court held that self-assessment tax paid due to failure of an initial IDS declaration must be treated as payment under the revived Scheme, preventing double taxation of the same income.
The High Court ruled that tax authorities cannot ignore a binding ITAT Special Bench decision under Section 264 merely because the department has appealed it. Judicial discipline requires adherence unless the ruling is stayed or overturned.
The issue was whether reassessment could be initiated beyond four years after a completed scrutiny assessment. The Tribunal held that reopening was barred as there was no failure to disclose material facts.
