Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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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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