Status (Previous Disclosure)
Background:- During the processing of return of income for AY 2020-2021, Central Processing Unit (“CPC”) erred in considering certain operating revenue twice and also made disallowances erroneously and certain advance payments of tax were missed to be considered. Intimation u/s 143(1) was issued by CPC on October 29, 2021 against which an application was filed by the company, for rectification u/s 154 with the Jurisdictional Assessing Officer (“AO”) and with the Faceless AO simultaneously by the Company. Dispute details:- An application has been filed with the Assessing Officer against the erroneous adjustments made by CPC during processing of the Company’s Income Tax return on various grounds like erroneous additions of item of incomes twice, disallowance of certain amount as expense, short grant of tax deducted at source and levying consequential interest thereon. This resulted in raising of tax demand of Rs. 32,97,47,360/- as against the refund claimed by the Company of Rs. 20,98,00,000/-. Thereafter, the Assistant Commissioner of Income Tax has forwarded Order of assessment in the application as mentioned above filed with the Assessing Officer against the erroneous adjustments made by CPC during processing of the Company’s Income Tax return is accepted in favour of the Company. The demand of Income Tax of INR 32,97,47,360/- as per the CPC Assessment is converted into a refund of INR 14,52,16,939/- as per the Assessment under Section 143(3) read with Section 144C(3) of the Income Tax Act, 1961. Hence, the proceedings before the Assistant Commissioner of Income Tax relating to said matter stands concluded. However, the said refund is below the refund claimed by the Company of INR 20,98,00,000/-. Hence, the company filed appeal in December 2023 before CIT (Appeals) to claim the deficit in refund of INR 64,583,061/-.