Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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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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