Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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The ITAT Ahmedabad considered rectification u/s 154 for correct assessment year of DDT. Revenue argued DDT pertained to A.Y. 2014-15, but Section 115-O(3) mandates DDT payment when dividend is declared. DDT must be accounted for in the year it was paid. Assessee rectified Form 3CD for A.Y. 2014-15 and 2015-16 to correct DDT accounting error. CIT(A) rejected revised form, stating it should have been filed before end of relevant assessment year. However, as dividend declaration and DDT payment occurred in A.Y. 2015-16, DDT should be accounted for in A.Y. 2015-16. Assessee's appeal allowed.
The ITAT Ahmedabad considered rectification u/s 154 for correct assessment year of DDT. Revenue argued DDT pertained to A.Y. 2014-15, but Section 115-O(3) mandates DDT payment when dividend is declared. DDT must be accounted for in the year it was paid. Assessee rectified Form 3CD for A.Y. 2014-15 and 2015-16 to correct DDT accounting error. CIT(A) rejected revised form, stating it should have been filed before end of relevant assessment year. However, as dividend declaration and DDT payment occurred in A.Y. 2015-16, DDT should be accounted for in A.Y. 2015-16. Assessee's appeal allowed.
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