Approval not obtained from PCIT as required under the new provisions – Reassessment notice declared invalid and assessment stood nullified: Mumbai ITAT
Approval not obtained from PCIT as required under the new provisions – Reassessment notice declared invalid and assessment stood nullified: Mumbai ITAT The judgment in the case of ACIT-19(1) v. Manish Financial [ I.T.A. No.5055/Mum/2024; Assessment Years: 2015-16 & 2016-17; Dt. of Judgement: 02.12.2024] [“D” Bench, Mum ITAT] stems from reassessment proceedings involving AYs2015-16 and… […]
Re-assessment notice issued U/s 148 being barred by limitation under the new provisions of section 149(1) is liable to be quashed and set aside.
Re-assessment notice issued U/s 148 being barred by limitation under the new provisions of section 149(1) is liable to be quashed and set aside. The “C” Bench of Mumbai ITAT in ITO v. Pushpak Realities Pvt. Ltd.( ITA No. 4812/Mum/2024; Date of Judgment: 07/11/2024; AY: 2015-16) [Mum ITAT] held that reassessment notice issued under… […]
Delay in filing Form 67 is a procedural lapse that does not affect the substantive right to claim FTC: ITAT
Delay in filing Form 67 is a procedural lapse that does not affect the substantive right to claim FTC: ITAT In a case before 𝗜𝗻𝗰𝗼𝗺𝗲 𝗧𝗮𝘅 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗼𝗻 𝗙𝗼𝗿𝗲𝗶𝗴𝗻 𝗧𝗮𝘅 𝗖𝗿𝗲𝗱𝗶𝘁, the following issues were involved 1. Denial of Foreign Tax Credit (FTC) due to procedural non-compliance (late filing of Form 67). 2. Whether FTC can be disallowed purely based… […]
GST Advisory: Reporting Differences in Tables 8A & 8C for FY 23-24
GST Advisory: Reporting Differences in Tables 8A & 8C for FY 23-24 The following are the Key Changes: Table 8A: Auto-populated from GSTR-2B for FY 23-24. Table 8C: Manual input for ITC availed in next FY till the cutoff date. Common Scenarios: 1 Late-reported invoices for FY 23-24 → Report in Table 8C &… […]
Delay in filing Form 67 is a procedural lapse that does not affect the substantive right to claim FTC: ITAT
Delay in filing Form 67 is a procedural lapse that does not affect the substantive right to claim FTC: ITAT In a case before Income Tax Tribunal on Foreign Tax Credit, the following issues were involved 1. Denial of Foreign Tax Credit (FTC) due to procedural non-compliance (late filing of Form 67). 2. Whether… […]
𝗜𝗻𝗰𝗼𝗺𝗲 𝗧𝗮𝘅 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗢𝗿𝗱𝗲𝗿 𝗼𝗻 𝗱𝗶𝘀𝗮𝗹𝗹𝗼𝘄𝗮𝗻𝗰𝗲 𝗼𝗳 𝗙𝗼𝗿𝗲𝗶𝗴𝗻 𝗧𝗮𝘅 𝗖𝗿𝗲𝗱𝗶𝘁
𝗜𝗻𝗰𝗼𝗺𝗲 𝗧𝗮𝘅 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗢𝗿𝗱𝗲𝗿 𝗼𝗻 𝗱𝗶𝘀𝗮𝗹𝗹𝗼𝘄𝗮𝗻𝗰𝗲 𝗼𝗳 𝗙𝗼𝗿𝗲𝗶𝗴𝗻 𝗧𝗮𝘅 𝗖𝗿𝗲𝗱𝗶𝘁 𝗞𝗲𝘆 𝗜𝘀𝘀𝘂𝗲𝘀: 1. Denial of Foreign Tax Credit (FTC) due to procedural non-compliance (late filing of Form 67). 2. Whether FTC can be disallowed purely based on delay in filing Form 67. 3. Application of Double Taxation Avoidance Agreement (DTAA) between India and Thailand. 𝗙𝗮𝗰𝘁𝘀… […]
Rs. 175 crore GST illegal Scam – HC verdict to release the Tax officer as there are procedural violations that render his detention null & void
Rs. 175 crore GST illegal Scam – HC verdict to release the Tax officer as there are procedural violations that render his detention null & void The copy of the Press News is as under: The post Rs. 175 crore GST illegal Scam – HC verdict to release the Tax officer as there are […]
Inadmissible credit utilized is output tax unpaid or credit liable to reversal or both?
Inadmissible credit utilized is output tax unpaid or credit liable to reversal or both? Credit maybe inadmissible for any reason – 16(2)(c), 17(2) or 17(5). Such credit is no credit at all, yet portal admits all credit into ECrL once claimed via 3B. Output tax maybe discharged out of balance in ECrL. And subject to… […]
Will the notice sent by the wrong officer invalidate the assessment proceeding?
Will the notice sent by the wrong officer invalidate the assessment proceeding? Upholding the order of the Tribunal quashing the assessment proceedings, the court held in Pr. CIT v. Shree Shoppers Ltd. [2024] 468 ITR 18 (Cal) that on the date when the assessee’s case was selected for scrutiny assessment under section 143(3), the authority who issued the… […]
Mere surrender of income would not absolve the assessee from the levy of penalty until and unless the mandatory provisions of Section 271AAA(2) has not been complied.
Mere surrender of income would not absolve the assessee from the levy of penalty until and unless the mandatory provisions of Section 271AAA(2) has not been complied. Whether it is mandatory for the assessee to comply with the condition of sub section 2 of Section 271AAA (Penalty where search has been initiated) in spite… […]
