Finance Act, 2021 has brought out sea-changes in the scheme of reassessment. Justice Shah termed the new scheme of reassessment in the famous case of Ashish Agrawal as ‘game changer’. Position of law in the matter of reopening which more or less came to be settled over the years by the law expounded & enunciated by Hon’ble…
Government’s quest to bring more and more payments within the TDS net seems to have prompted section 194T to come on the statute by the Finance (No. 2) Act, 2024 w.e.f. 01.04.2025. Section 194T reads as under: Payments to partners of firms. 194T. (1) Any person, being a firm, responsible for paying any sum in the…
IntroductionChapter XXI of Income Tax Act, 1961 is replete with penal provisions right from section 270A to section 272BBB. Section 271AAD introduced by the Finance Act, 2020 is the latest addition to an already existing large family of penalties. This penalty provision contained in section 271AAD is quite harsh and throws several interpretational issues. It is, therefore, expedient…
Income Tax Appellate Tribunal (hereinafter ‘Tribunal’) passes order on the strength of the power conferred by section 254(1). Power to rectify the apparent mistakes from record in such order is enshrined under sub section (2) to section 254. Before we move further, it is expedient that sub section (1) & (2) of Section 254 are…
Introduction & Background Various actions & proceedings contemplated under the Income Tax Act, 1961 (hereinafter called “Act’) are time bound. This is because of the ‘limitations’ prescribed under the various sections of the Act. Time limitations are prescribed for compliances of myriads of statutory & also other beneficial requirements meant for the tax payers which are, most of the…
Preface & Introduction Present time may not be the best time to discuss a recently introduced depressing attempt & regressive amendment made to section 254(2A) of the Income Tax Act, 1961 by the Legislature, given an all pervading state of despondency due to the spread of COVID -19 pandemic. The spanner thrown by the legislature this time & enacted…
