Delhi High Court Clarifies When Penalty Proceedings Are ‘Initiated’ Under Section 271C of the Income Tax Act for TDS Non-Compliance

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By clarifying that penalty initiation begins from the earliest action, such as a reference from the AO, the Delhi High Court underscores that delays in issuing show-cause notices do not extend the penalty imposition timeline. In a recent ruling, the …

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Kerala High Court Rules Assessing Authorities Can’t Reassess Past Years Without Inquiry in Current-Year Cases

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The Court questioned how, during assessment proceedings for 2011-12, the authorities could examine the business nature and extent of the assessee’s activities dating back to 1999-2000. In a significant judgment in Kings Infra Ventures Ltd vs. ACIT (ITA No. 28/2023), …

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ITAT Bangalore Rejects Disallowance of Interest-Free Advance to Related Party Under Section 36(1)(iii) of the Income Tax Act

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The ITAT ruled that, as long as interest-free funds are sufficiently available at the time of advance, disallowance of interest on subsequent loans will not stand. In this article, we delve into a notable tax judgement of ITAT involving a …

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Monetary Limits for Reduction or Waiver of Interest under Section 220(2) of the Income Tax Act: CBDT Circular 15/2024

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Under Section 220(2A), certain income tax authorities have the power for reduction or waiver of interest, upon satisfaction of certain condition. Reduction or Waiver of Interest: The Central Board of Direct Taxes (CBDT) has recently issued Circular No. 15/2024 on …

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CBDT Notification 5/2024 Specifying Forms for Rollback of ADA & Claiming Deductions for Qualified Agricultural Extension Projects

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CBDT Specified Forms Prescribed in Appendix II of IT Rules 1962, to be Furnished Electronically under Sub-rule (1) & (2) of Income Tax Rules 1962. The Central Board of Direct Taxes (CBDT) has issued Notification No. 5/2024, which mandates the …

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Delhi High Court Mandates Proper Reasoning in Rejection of Condonation Application u/s. 119(2)(b) of Income Tax

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The court emphasized that Section 119(2)(b) is a beneficial provision, intended to allow for exceptions and refunds in cases of genuine hardship. Decisions made under this provision must include proper justification, aligning with both procedural fairness and the legislative intent …

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Income Tax Authorities Empowered to Accept Delayed Refund or Loss Carry Forward Claims under Section 119(2)(b) – Circular No. 11/2024

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No condonation application will be entertained by Income Tax Authorities beyond five years from the end of the relevant assessment year. Power of Income Tax Authorities in condoning delays in filing returns that claims refunds/ carry forward of losses: In …

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