9911796707
TMI Blog2022 (6) TMI 451X X X X Extracts X X X X X X X X Extracts X X X X ..... on the entire interest amount at the time of payment on cash basis, since the same would amount to double taxation. Therefore, the order of Ld. CIT(A) is set aside and the appeal of the assessee is allowed. - ITA No. 61/Ahd/2022 - - - Dated:- 8-6-2022 - Shri Waseem Ahmed, Accountant Member And Shri Siddhartha Nautiyal, Judicial Member For the Assessee : Shri P.D. Shah, A.R. For the Revenue : Shri Abhimanyu Singh Yadav, Sr. D.R. ORDER PER : SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER:- This is an appeal filed by the assessee against the order of the National Faceless Appeal Centre (NFAC), Delhi in DIN Order No. ITBA/NFAC/S/250//2020-21/1037106666(1) vide order dated 22/11/2021 passed for the assessment year 2017-18. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erest income accrued. However, during the year under consideration, TDS was deducted by the deductor on cash basis on the entire amount. Accordingly, the return of income was processed under section 143(1)(a) of the Act in which income from other sources was taken by CPC at ₹ 6,01,000/- as against ₹ 1,31,493/- considered in the return filed by the assessee. Subsequently, the assessee filed rectification application under section 154 of the Act before CPC, who rejected the assessee s rectification application. In appeal, the Ld. CIT(A) dismissed the assessee s appeal with the following observations: 3.0 Present appeal is filed against the intimation issued by the CPC in response to rectification filed by the appellant u/s 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... earlier years on accrual basis. Therefore, it was submitted that if the entire maturity amount of ₹ 6,01,000 is again subject to tax in the impugned year, it would amount to double taxation since the annual interest amount has already been offered to tax in various previous years on accrual basis. The assessee also furnished a Chart / Table before us in which he has tabulated the amount of interest income earned by the assessee on the aforementioned bonds since assessment year 2011-12 till 2017-18 on annual basis. The Ld. Counsel for the assessee also submitted copies of acknowledgement of return of income for the various years in support of the fact that the interest income which has accrued on annual basis has been offered to tax in ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
