Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
The ITAT upheld the rejection of the rectification application filed under section 154, affirming that interest income received under section 244A on income tax refunds is taxable as "income from other sources" and must be disclosed in the relevant assessment year. The tribunal distinguished this interest from government-held funds, clarifying that the interest pertains to excess tax paid by the assessee and not government monies. The adjustment of the refund and interest against outstanding demands does not excuse non-disclosure. The tribunal held that the issue of taxability required proper adjudication and could not be rectified as a mistake apparent from record. Consequently, the rectification was correctly denied, and since the assessee failed to challenge the matter through a regular appeal under the assessment order, the appeal was dismissed.
The ITAT upheld the rejection of the rectification application filed under section 154, affirming that interest income received under section 244A on income tax refunds is taxable as "income from other sources" and must be disclosed in the relevant assessment year. The tribunal distinguished this interest from government-held funds, clarifying that the interest pertains to excess tax paid by the assessee and not government monies. The adjustment of the refund and interest against outstanding demands does not excuse non-disclosure. The tribunal held that the issue of taxability required proper adjudication and could not be rectified as a mistake apparent from record. Consequently, the rectification was correctly denied, and since the assessee failed to challenge the matter through a regular appeal under the assessment order, the appeal was dismissed.
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