ITO v. Gas and Power Investment Co. Ltd. (2025) 125 ITR 489 / 174 taxmann.com 341 (Mum.)(Trib.)

S. 147: Reassessment- Income from other sources-Interest reflected in Form 26AS-No actual receipt-Addition deleted- Reassessment was invalid.[S. 56, 148, Form No. 26AS]

The reassessment was based solely on tax deducted at source reflected in Form 26AS showing interest income. The assessee, a Government special purpose company, established through audited accounts, bank statements and Accounting Standard-9 that no interest had actually been received during the relevant year. The Tribunal held that mere reflection of tax deducted at source in Form 26AS could not justify taxation in the absence of accrual or receipt of income. The deletion of the addition by the Commissioner (Appeals) was upheld.  Reassessment was quashed. (AY. 2014-15 to 2017-18).

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