https://www.taxtmi.com/caselaws?id=757055 Delhi HC quashed reassessment proceedings u/s 148A where tax authorities alleged interest income from NCDs was mischaracterized and should be taxed as dividend under DDT provisions. Court found manifest variation between initial reasons and final order, lacking required connection between proposed reassessment basis and final decision. Additionally, petitioner was merely recipient of interest income, not the entity declaring/paying dividend, making DDT liability inapplicable. Even if payment constituted dividend, tax liability would fall on the company declaring it, not the recipient. en-us Thu, 08 Aug 2024 00:00:00 +0530 Tue, 13 Aug 2024 16:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757055 Delhi HC quashed reassessment proceedings u/s 148A where tax authorities alleged interest income from NCDs was mischaracterized and should be taxed as dividend under DDT provisions. Court found manifest variation between initial reasons and final order, lacking required connection between proposed reassessment basis and final decision. Additionally, petitioner was merely recipient of interest income, not the entity declaring/paying dividend, making DDT liability inapplicable. Even if payment constituted dividend, tax liability would fall on the company declaring it, not the recipient. Case-Laws Income Tax Thu, 08 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757055