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 issue was whether exemption under Section 11 could be denied solely due to wrong data punching. The court ruled that inadvertent human errors cannot defeat a lawful exemption
The Delhi High Court held that sponsorship payments included consideration for worldwide use of event trademarks. The ruling confirms that such rights constitute royalty liable to withholding tax.
Uttarakhand High Court held that order of the Competent Authority granting sanction or approval or refusing to grant sanction or approval u/s 151 of the Income Tax Act of 1961 is neither a revisable order, nor an appealable order.
The Tribunal held that penalties under Section 271D were invalid as they were imposed beyond the limitation period prescribed under Section 275(1)(c).
Karnataka High Court held that revision petition u/s. 264 of the Income Tax Act wrongly dismissed by holing that delay in filing revision petition cannot be condoned since the revisional authority already condoned the delay.
The Court held that relief cannot be denied under Section 264 merely because a similar issue was earlier pending before the Supreme Court. The revision application was allowed as the issue was already covered by binding High Court rulings.
The dispute centered on whether DRP directions allow completion of assessment beyond statutory time limits. The Tribunal clarified that section 144C does not create an independent limitation period. Procedural timelines cannot defeat the mandatory bar under section 153.
The Tribunal held that limitation under Section 153 overrides the DRP timeline under Section 144C. As the assessment was completed beyond the statutory outer limit, it was quashed as invalid.
The Tribunal held that a final assessment passed after the expiry of Section 153 is invalid, even if it follows DRP directions. The is that limitation under Section 153 remains mandatory and cannot be bypassed through the DRP route.
The Tribunal held that the assessee cannot suffer due to the AO’s inaction under section 270AA(4), directing grant of immunity and cancelling the 270A penalty.
