Application for Revision Income u/s.264 of the I.T Act

[PRIYAM KHAMBHATA]

Respected Sir,

`A'-Charitable Trust filed ITR u/s. 139 (1), with claiming Refund of Rs.100000 for AY 2014-15. It was processed and net demand raised of Rs. 50000. But, `A'-Charitable Trust had received neither Intimation u/s. 143 (1) of the Income Tax Act, nor any communication for demand outstanding of AY 2014-15. When finalization of audited accounts of 2021-22, `A' Charitable Trust has noticed that TDS of Rs.100000 of AY 2014-15 has standing in the books of accounts, it means TDS - Refund has not still received. Therefore, it has filed Grievance on CPC Portal in June 2022, that Intimation 143 (1) not received of AY 2014-15. It has been resolved by CPC and sent Intimation u/s. 143 (1), dated 16.01.2016 of AY 2014-15 through registered email on 22.06.2024. On verification of the Intimation 143(1), it came to knowledge that while processing the Return, deduction claimed u/s. 11(2) has disallowed and income enhanced, accordingly, Tax demand raised.

In view of the above scenario, can `A' - Charitable Trust would file Revision Application before Pr. CIT, to rectify the total income as per Intimation 143(1) of the Income Tax Act, dated of AY 2014-15, on the basis of communication received from CPC, via email dated 22.06.2024.

Please guide me.

AI Summary

Tax Deduction Dispute: Charitable Trust Challenges Delayed Intimation Under Section 11(2) and Section 264 A charitable trust filed an income tax return for AY 2014-15, claiming a refund. An intimation under Section 143(1) was issued in 2016 but not communicated until 2024, disallowing a deduction under Section 11(2). The trust seeks to file a revision application under Section 264 of the Income Tax Act to challenge the intimation, arguing that the limitation period starts from the actual date of communication in 2024.