The CBDT vide Circular No. 18\/2024 has extended the due date for furnishing the Return of Income for the Assessment Year 2024-25 for assessees required to furnish a TP report. The due date has been extended from 30th November 2024 to <\/span>15th December 2024<\/b>.<\/span><\/p>\n The CBDT has notified on 28<\/span>th<\/span> Nov, 2024; that the provisions of section 194N shall not apply to Foreign Representations duly approved by the Ministry of External Affairs of the Government of India, including Diplomatic Missions, agencies of the United Nations, International Organizations, Consulates and Offices of Honorary Consuls which are exempt from paying taxes in India.<\/span><\/p>\n The CBDT vide Press Release dated 26.11.2024 release FAQ\u2019s on PAN 2.0 project to streamline and modernise process of issuing and managing pan and tan, making it simpler, more userfriendly and efficient.<\/span><\/p>\n The CBDT vide notification notifies electronic filing of Forms 42, 43 & 44 in respect of provident fund, \u00a0superannuation fund and gratuity fund.<\/span><\/p>\n The CBDT vide circular 15\/2024 specifies monetary limits for reduction or waiver of interest paid or payable under section 220(2).<\/span><\/p>\n [2024] 168 taxmann.com 543 (Delhi-HC) Sipura Developers Pvt Ltd vs. PCIT<\/i><\/b><\/p>\n Where Assessing Officer had already accepted assessee’s explanation regarding investment made in shares and amount borrowed by assessee for funding said purchase, Assessing Officer could not proceed to make any addition on any other ground in reassessment proceedings and, therefore, non-addition of any income would not confer Commissioner with jurisdiction to pass an order under section 263.<\/span><\/p>\n [2024] 168 taxmann.com 574 (Delhi-HC) PCIT -7 vs. Naveen Kumar Gupta<\/i><\/b><\/p>\n Where Assessing Officer initiated reassessment proceedings based on material which included information found during search conducted in respect of another person and information as obtained from Investigation Wing, since jurisdictional conditions to initiate further steps under section 153C were not satisfied, non obstante clause as used in section 153C couldnot be read to completely exclude provisions of section 147 and thus, decision of Assessing Officer to reassessee income of assessee under section 147 could not be faulted.<\/span><\/p>\n [2024] 168 taxmann.com 565 (Mumbai – Trib.)\u00a0Colathur N. Ram vs. ACIT<\/i><\/b><\/p>\n Section 54 of the Income-tax Act, 1961 – Capital gains – Profit on sale of property used for residence (Purchase of new house) – Assessment year 2013-14 – Whether for qualifying exemption under section 54, it is necessary and applicable to have investments made in residential house in name of assessee only – Held, yes – Whether, therefore, where assessee sold a residential house and invested sale consideration in purchase of two residential flats in same building in name of his wife and son, assessee would not be eligible for claiming exemption under section 54 – Held, yes [Para 14] [In favour of revenue]<\/span><\/p>\n [2024] 169 taxmann.com 11 (Mumbai – Trib.)\u00a0Jitendra Gala Navneet Trust vs. DCIT<\/i><\/b><\/p>\n Assessee-trust filed return of income declaring total income at Rs. 6.73 lakhs – Assessing Officer assessed income of assessee at Rs. 6.73 lakhs and levied a surcharge at rate of 37 per cent as against nil computed by assessee – Whether since as per first schedule to Finance Act, 2022 only when total income exceeded Rs. 50 lakhs then surcharge was leviable and in instant case income of assessee was assessed at Rs. 6.73 lakhs which was less than Rs. 50 lakhs, levying of surcharge would not be applicable for same – Held, yes [Para 12] [In favour of assessee]<\/span><\/p>\n [2024] 167 taxmann.com 503 (Kolkata – Trib.)\u00a0L & T Finance Ltd. vs. DCIT<\/i><\/b><\/p>\n Where assessee-company incurred Corporate Social Responsibility (CSR) expenditure as mandatorily required under section 135 of Companies Act, 2013 and out of total CSR expenditure, certain expenditure was made by way of donations to eligible institutions under section 80G, assessee was not barred from claiming deduction under section 80G in respect of donations made to approved institutions even though same was made in discharge of CSR obligation.<\/span><\/p>\n [2024] 168 taxmann.com 363 (SC)\u00a0Mahendra Gala vs. ITO<\/i><\/b><\/p>\n Where relationship between vendor and vendee was that of mother and son, reference to circle rate, which might be relevant for purpose of execution of a sale deed\/gift deed, had no relevance to invoke section 50C.<\/span><\/p>\n Related Services : Tax Preparation Services<\/a>\u00a0 Direct Tax Services<\/a><\/strong><\/p>\n","protected":false},"excerpt":{"rendered":" Due date for filing ITR for AY 2024-25 for assessee required to furnish TP report extended till 15-12-2024: CBDT The CBDT vide Circular No. 18\/2024 has extended the due date for furnishing the Return of Income for the Assessment Year 2024-25 for assessees required to furnish a TP report. The due date has been extended from 30th November 2024 to […]<\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":"","_links_to":"","_links_to_target":""},"categories":[16],"tags":[],"class_list":["post-2241","post","type-post","status-publish","format-standard","hentry","category-direct-tax"],"yoast_head":"\nNo Sec. 194N TDS on cash withdrawal by foreign representations approved by Ministry of External Affairs: CBDT<\/h3>\n
CBDT releases FAQs on PAN 2.0 project; PAN\/TAN services shall be completely paperless<\/h3>\n
NOTIFICATION NO. 6\/2024,\u00a0DATED 19-11-2024<\/h4>\n
CIRCULAR NO. 15\/2024 [F. NO. 400\/08\/204-IT(B)],\u00a0DATED 4-11-2024<\/h4>\n
Important Judicial Precedents<\/b><\/h2>\n
No sec. 263 revision if AO accepted explanation on share investment during reassessment: HC<\/h3>\n
AO can initiate reassessment with info from investigation wing and search of another Co: HC<\/h3>\n
Sec. 54 exemption not available if new house is purchased in name of wife & son instead of assessee’s name<\/h3>\n
Trust not liable to pay surcharge just because its income is taxable at maximum marginal rate: ITAT<\/h3>\n
CSR exp. doesn\u2019t bar Co. from claiming sec. 80G deduction for donations to approved institutions: ITAT<\/h3>\n
SC granted Stay on reassessment as sale deed executed between mother & son not covered u\/s 50C provisions<\/h3>\n