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Income Tax - Highlights / Catch Notes

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The ITAT reviewed a case involving the revision u/s 263 ...


Revision u/s 263: Interest income on Core Settlement Guarantee Fund not taxable. ICCL controls funds. Income exempt u/s 10(23EE).

Case Laws     Income Tax

June 11, 2024

The ITAT reviewed a case involving the revision u/s 263 regarding the accrual of interest income on contributions made by the assessee towards Core Settlement Guarantee Fund. The CIT held that the AO erred in not examining the taxability of the accrued interest income before allowing its application in the accounts. The ITAT found that the contributions to the fund were under the control of ICCL and created to safeguard investors' interests, with any income accrued being exempt u/s 10(23EE) of the Act. The ITAT determined that the AO had collected and verified relevant information, and the PCIT did not demonstrate how the income earned by ICCL was chargeable to tax in the assessee's hands. The ITAT concluded that while the AO's order may be considered erroneous, it did not meet the condition of being prejudicial to revenue, ruling in favor of the assessee.

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