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Income Tax - Highlights / Catch Notes

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Exempt dividend income treated as taxable, increasing total ...


Dividend income taxability, intra-group services' TP adjustment through APA, CSR deduction clarification, interest on late filing, DDT credit verification.

Case Laws     Income Tax

November 27, 2024

Exempt dividend income treated as taxable, increasing total income - claim denied by processing return u/s 143(1). Assessee filed rectification application u/s 154 pending before CPC, Bengaluru. Application to be disposed expeditiously, and no adverse action against assessee till disposal. TP adjustment on intra-group support services - settled through unilateral APA between CBDT and assessee for 5 years from 2015-16 to 2019-20, including assessment year. AO to re-decide issue considering APA and modified return. Deduction u/s 80G for CSR expenditure - DRP concluded deduction allowed except for donations to Swachh Bharat Kosh and Clean Ganga Fund, subject to section 80G conditions. Issue remanded to AO to pass final order conforming to DRP directions. Interest u/s 234A - challenged on grounds of timely filing before extended due date. AO to verify extended date and levy interest only if return filed after extended date. Interest u/s 234B to be levied by AO after giving appeal effect. Non-granting of DDT credit - AO to verify claim from challan and allow credit if correct.

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