2025 (6) TMI 2162

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... the petitioner challenging the impugned assessment order dated 11.03.2025, passed by the 1 st respondent, relating to the Assessment Year 2023-2024. 2. Mr. P.S. Raman, learned Senior Counsel assisted by Mr. Gauthama Raj, learned counsel for the petitioner would submit that, the present dispute pertains to the Assessment Year 2023-2024. The impugned order has been passed disallowing a sum of Rs. 2,49,92,01,086/-, stating the same fall within the purview of Section 40(a)(ia) of the Income Tax Act. The petitioner received deposits from various types of depositors, who all are exempted entities under the Income Tax Act and to those entities, if any interest on deposits are paid since they are all exempted entities, they are not required to ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....x time limit to dispose of the said appeals and appropriate orders may be passed to defer the recovery proceedings till such time. 4. Dr. B. Ramaswamy, learned Senior Standing Counsel appearing for the respondents by referring paragraph Nos. 4, 5 and 6 of the counter affidavit would submit that the order passed under Section 143(3) read with Section 144B for Assessment Year 2023-2024, disallowing Rs.2,49,92,01,086/- under Section 40(a)(ia), is strictly in accordance with statutory provisions. However, since this Court stayed the assessment order dated 28.02.2024 till the disposal of the appeals pending before the Appellate Authority on condition to the petitioner to pay Rs.30 Crores out of the disputed tax amount, two months time may be ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... both sides fought tooth and nail regarding the demand of 20% of the disputed tax, which comes around to a sum of Rs.126 crore, considering the submission of the learned counsel for the petitioner that the petitioner has voluntarily come forward to deposit Rs.30 Crore, to which even the learned Senior Standing Counsel for the respondents is not agreeable, this Court, considering the vital fact that the petitioner is a state Owned Corporation and it plays an anchor role to the development of Power Sector Projects in the State of Tamil Nadu, as it executes an array of welfare schemes of the Government of Tamil Nadu like i) Child Protection Scheme, Covid-19 Protection Scheme, Oru Kalla Pooja Schemes, etc., also, the Pension Funds of the State ....