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Posted: 12 Apr 2013 02:41 AM PDT
Central Direct Tax Advisory Committee (CDTAC) is to Develop and Encourage Mutual Cooperation between the Tax-Payers and the Income Tax Department and to Remove Administrative and Procedural difficulties of a General Nature: FM The Union Finance Minister Shri P. Chidambaram said that role of the...
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KEY NOTE: Ref. Above and Previous ;
CAUTION > NOT TO BE READ TOGETHER, in same breath (without any number of pinches of salt according to individual' s taste or distate, - nay, individualistic demenour or tensile strength, or disgestivity) !!!!!!!????????
<previous
Taxation of Income and Levy of Tax twice over ?
On Writ of 'Mandamus' (?)>
Writ of Mandamus: What Is It About? | Indian Law
www.lawisgreek.com › Legal TipsMay 31, 2010 – The term “mandamus” literally means “command.” Writ of mandamusis issued to a person or lower level Court or a body by a superior Court.writ of mandamus - Indian Kanoon
indiankanoon.org/search/?formInput=%20writ%20of%20mandamusCorporation from obligation to carry out the Writ of Mandamus issued by the Single Judge. Constitution of India ... Corporation from its obligation to carry out the ...Analysis Of Writ Of Mandamus - Legal Services India
www.legalservicesindia.com/.../analysis-of-writ-of-mandamus-592-1....Mar 15, 2011 – In India Article 32 and 226 of the Constitution gives power to the Supreme Court and High Court to issue writs in case of breach of Fundamental ...Key points regarding writ of mandamus - Constitutional Law Articles ...
www.lawyersclubindia.com › Articles › Constitutional LawMar 12, 2009 – Mandamus means a command. It is issued in favour of a person who establishes his legal rights and against aperson who has a legal duty but ...What is Writ of Mandamus and when is it used?
www.vakilsearch.com/law/writ/writ-petition/writs...india/mandamusWhat is a Writ of Mandamus? Contributed under writ petition; by Vijay Sekar. Writ of Mandamus can be filed, as per our constitution under Article 32 in the ...
1. Section 234E - Fee for default in furnishing statements - of - Income ...
www.taxmanagementindia.com/visitor/detail_act.asp?ID=16595
Section 234E - Fee for default in furnishing statements - of - Income-tax Act, 1961 - Income Tax DTAA Income Tax Act 1961,2. Excerpts from Del. HC Order @SG >
<> II . 11. Office of the Commissioner of Income Tax, Bengaluru, realising that huge amount has been claimed as tax arrears, had written a letter dated 21st August, 2012, to all Chief Commissioners. The relevant portion of the said letter reads as under:
“Kind reference is invited to the above, wherein the assessing officers have been instructed to verify and reconcile the demands where such demand or adjustment thereof by CPC is disputed by the taxpayer. They have also been advised to upload amended figure of arrear demand on the Financial Accounting System (FAS) portal of Centralized Processing Center (CPC), Bengaluru wherever there is balance outstanding arrear demand still remaining after aforesaid correction/reconciliation.
10. Inspite of the said effort and direction, the CBDT/Board accepts and admits the position that incorrect and wrong demands have been uploaded. This is clear from the further directions which have been issued by the Board to the Assessing Officers on 30th September, 2010, 9th November, 2010 and 15th February, 2012. The aforesaid demands relate to the period on or before 31st March, 2010. In the counter affidavit, it is indicated that 46.34 lac entries of demand aggregating to Rs. 2.32 lac crores have been uploaded on the CPC arrear demand portal by the Assessing Officers.
Para 7 The problem was apparent, real and enormous and had escalated because of centralised computerisation and problems associated with the incorrect and wrong data which was uploaded by the tax deductors or payers and the Assessing Officers. The issue was of general governance, failure of administration,fairness nd arbitrariness.
13. The CBDT, after issue of notice in the writ petition, has issued Circular No. 4 of 2012, which read as under:
“The Board has been apprised that in certain cases the assessees have disputed the figures of arrear demands shown as outstanding against them in the records of the Assessing Officer. The Assessing Officers have expressed their inability to correct/reconcile such disputed arrear demand on the ground that the period of limitation of four years as provided under sub section (7) of section 154 of the Act has expired.
Further, in some cases, the Assessing Officers have uploaded such disputed arrear demand on the Financial Accounting system (FAS) portal of Centralized Processing Centre (CPC), Bengaluru which has resulted in adjustment of refund arising out of processing of Returns against such arrear demand which has been disputed by such assessees on the grounds that either such demand has already been paid or has been reduced/eliminated in the appeals, etc. The arrear demands, in these cases also were not corrected/reconciled for the reason that the period of limitation of our years has elapsed.
2. The Board, in consideration of genuine hardship faced by the abovementioned class of cases, in exercise of powers vested under Section 119(2)(b) of the Act, hereby authorise the Assessing Officers to make appropriate corrects in the figures of such disputed arrear demands after due verification / reconciliation and after examining the same on merits, whether by way of rectification or otherwise, irrespective of the fact that the period of limitation of four year as provided under Section 154(7) of the Act has elapsed.
33. The second grievance of the assessee is with regard to the uncommunicated intimiations under Section 143(1) which remained on paper/file or the computer of the Assessing Officer. This is serious challenge and a matter of grave concern. The law requires intimation under Section 143(1) should be communicated to the assessee, if there is an adjustment made in the return resulting either in demand or reduction in refund. The uncommunicated orders/intimations cannot be enforced and are not valid. Respondents in the counter affidavit have not dealt with this problem on the assumption that the Assessing Officer who had manually processed the returns and passed the order/intimations under Section 143(1) would have necessarily followed the statute and communicated the said orders/intimations. In case the said orders/intimations under Section 143(1) were communicated or dispatched to the assessees, the directions given by us below would not be a cause for any grievance and will not be a matter of concern for the Revenue. We also accept the contention of the Revenue that where an order under Section 143(1) was sent and communicated to the assessee but could not be served due to non-availability/change of address or other valid reasons, should not be treated at par with cases where there is no communication or no attempt is made to serve the order whatsoever. But when there is failure to dispatch or send communication/intimation to the assessee consequences must follow. Such intimation/order prior to 31st March, 2010, will be treated as non est or invalid for want of communication/service within a reasonable time. This exercise, it is desirable should be undertaken expeditiously by the Assessing Officers. CBDT will issue instructions to the Assessing Officers.
34. The onus to show that the order was communicated and was served on the assessee is on the Revenue and not upon the assessee. We may note in case an order under Section 143(1) is not communicated or served on the assessee, the return as declared/filed is treated as deemed intimation and an order under Section 143(1). Therefore, if an assessee does not receive or is not communicated an order under Section 143(1), he will never know that some adjustments on account of rejection of TDS or tax paid has been made. While deciding applications under Section 154, or passing an order under Section 245, the Assessing Officers are required to know and follow the said principle. Of course, while deciding application under Section 154 or 245 or otherwise, if the Assessing Officer comes to the conclusion and records a finding that TDS or tax credit had been fraudulently claimed he will be entitled to take action as per law and deny the fraudulent claim of TDS etc. The Assessing Officer, therefore, has to make a distinction between fraudulent claims and claims which have been rejected on ground of technicalities but there is no communication to the assessee of the order/intimation under Section 143(1). In the later cases, the Assessing Officer cannot turn around and enforce the demand created by uncommunicated order/intimation under Section 143(1). This is the fifth mandamus which we have issued.
The related Notification and some Circulars are reproduced below:: >>>>
33. The second grievance of the assessee is with regard to the uncommunicated intimiations under Section 143(1) which remained on paper/file or the computer of the Assessing Officer. This is serious challenge and a matter of grave concern. The law requires intimation under Section 143(1) should be communicated to the assessee, if there is an adjustment made in the return resulting either in demand or reduction in refund. The uncommunicated orders/intimations cannot be enforced and are not valid. Respondents in the counter affidavit have not dealt with this problem on the assumption that the Assessing Officer who had manually processed the returns and passed the order/intimations under Section 143(1) would have necessarily followed the statute and communicated the said orders/intimations. In case the said orders/intimations under Section 143(1) were communicated or dispatched to the assessees, the directions given by us below would not be a cause for any grievance and will not be a matter of concern for the Revenue. We also accept the contention of the Revenue that where an order under Section 143(1) was sent and communicated to the assessee but could not be served due to non-availability/change of address or other valid reasons, should not be treated at par with cases where there is no communication or no attempt is made to serve the order whatsoever. But when there is failure to dispatch or send communication/intimation to the assessee consequences must follow. Such intimation/order prior to 31st March, 2010, will be treated as non est or invalid for want of communication/service within a reasonable time. This exercise, it is desirable should be undertaken expeditiously by the Assessing Officers. CBDT will issue instructions to the Assessing Officers.
34. The onus to show that the order was communicated and was served on the assessee is on the Revenue and not upon the assessee. We may note in case an order under Section 143(1) is not communicated or served on the assessee, the return as declared/filed is treated as deemed intimation and an order under Section 143(1). Therefore, if an assessee does not receive or is not communicated an order under Section 143(1), he will never know that some adjustments on account of rejection of TDS or tax paid has been made. While deciding applications under Section 154, or passing an order under Section 245, the Assessing Officers are required to know and follow the said principle. Of course, while deciding application under Section 154 or 245 or otherwise, if the Assessing Officer comes to the conclusion and records a finding that TDS or tax credit had been fraudulently claimed he will be entitled to take action as per law and deny the fraudulent claim of TDS etc. The Assessing Officer, therefore, has to make a distinction between fraudulent claims and claims which have been rejected on ground of technicalities but there is no communication to the assessee of the order/intimation under Section 143(1). In the later cases, the Assessing Officer cannot turn around and enforce the demand created by uncommunicated order/intimation under Section 143(1). This is the fifth mandamus which we have issued.
A. Section 143 of the Income-tax Act, 1961 - Assessment - General - Specified provisions of the Act which shall apply to Centralised Processing of Returns Scheme, 2011
Notification No. 3/2012 [F. No. 142/27/2011-SO (TPL)] SO 17(E), dated 4-1-2012
In exercise of powers conferred by sub-section (1B) of section 143 of Income Tax Act, 1961 (43 of 1961), for the purpose of giving effect to the Centralised Processing of Returns Scheme, 2011 made under sub-section (IA) of section 143 of the said Act, the Central Government hereby directs that, the following provisions of the Act relating to processing of returns shall not apply or shall apply with such exceptions, modifications and adaptations as specified hereunder, namely: -
1. This notification shall come into force on the date of its publication in the Official Gazette.
2. The provisions of section 139 of the Act shall apply to returns received under Centralised Processing of Returns Scheme, 2011 subject to the following, namely :-
A. (i) All ITR-V (acknowledgement) forms duly verified shall be sent to the Centralised Processing Centre, either through ordinary or speed post, within such period of uploading the electronically filed return as may be specified by the Director General in this behalf.
(ii) The date of transmitting the data electronically shall be the date of furnishing the return if the Form ITR-V is furnished in the prescribed manner and within the specified period.
(iii) In case Form ITR-V furnished after the prescribed time is rejected on account of it being unsigned, illegible, mutilated, bad quality or not as per specification, it shall be deemed that the return in respect of which the Form ITR-V has been filed was never furnished and it shall be incumbent on the person to electronically file the return of income again and follow it up by submitting the new Form ITR-V.
(iv) The Form ITR-V shall be submitted at the address, in the mode and within the period or extended period specified in this behalf.
(v) The Commissioner Centre may, in order to avoid hardship in a case or class of cases, condone the delay in receipt of Form ITR-V.
(vi) The Centre may call for fresh Form ITR-V in special circumstances, where the Form ITR-V submitted earlier cannot be considered for technical reasons.
B. (i) If the original return of income is an electronically filed return, the revised return shall be filed through electronic mode only.
(ii) The Centre shall process only the revised return and no further action shall be taken on original return if it has not already been processed.
(iii) The Commissioner may declare-
(a) a return invalid for non-compliance of procedure for using any software not validated and approved by the Director General;
(b) a return defective under sub-section (9) of section 139 of the Act on account of incomplete or inconsistent information in the return or in the schedules or for any other reason.
C. (i) In case of a defective return, the Commissioner shall intimate this to the person through e-mail or by placing a suitable communication on the e-filing website.
(ii) A person shall comply with the notice regarding defective return by uploading the rectified return within the period of time mentioned in the notice.
(iii) The Commissioner may, in order to avoid hardship to the person, condone the delay in uploading of rectified return.
(iv) In case no response is received from the person in reply to the notice of defective return, the Commissioner may declare a return as not having been uploaded at all or process the return on the basis of information available.
D. (i) A person shall not be required to appear either personally or through authorised representative before the authorities at the Centre in connection with any proceedings.
(ii) Written or electronic communication from such person or authorised representative in the format specified by the Centre in this respect shall be sufficient compliance of the query or clarification received from the Centre.
3. The provisions of section 143 of the Act shall apply to all returns received under the Centralised Processing of Returns Scheme, 2011 subject to the following, namely:-
(i) the sum payable to, or the amount of refund due to, the person shall be determined after credit of such Tax collected at Source (TCS), Tax Deducted at Source (TDS) and tax payment claims which can be automatically validated with reference to data uploaded through TDS and TCS statements by the deductors or the collectors, as the case may be, and tax payment challans reported through authorised banks in accordance with business rules laid out by the Centre in this regard;
(ii) an intimation shall be generated electronically and sent to the person by e-mail specifying the sum determined to be payable by, or the amount of the refund due to, the person;
(iii) any intimation to the person to pay any sum determined to be payable shall be deemed to be a notice of demand as per the provisions of section 156 of the Act and all other provisions of the Act shall be accordingly applicable.
(iv) The Commissioner may,-
(a) adopt appropriate procedures for processing of returns; and
(b) decide the order of priority for processing of returns of income based on administrative requirements.
(v) Wherever a return cannot be processed in the Centre for any reason, the Commissioner shall arrange to transmit such return to the Assessing Officer having jurisdiction for processing.
(vi) The Centre may call for such clarification, evidence or document as may be required for the purpose of facilitating the processing of return and all such clarification, evidence or document shall be furnished electronically.
4. The provisions of section 154 of the Act shall apply to all the returns received under the Centralised Processing of Returns Scheme, 2011 subject to the following, namely:-
(i) An application for rectification shall be filed electronically to the Centre in the format prescribed and shall be processed in the same manner as an Income-tax return.
(ii) In case of error in processing due to an error in data entry or a software error or otherwise, resulting in excess refund being computed or reduction in demand of tax, the same will be corrected on its own by the Centre by passing a rectification order and the excess amount shall be recovered as per the provisions of the Act.
(iii) Where a rectification has the effect of enhancing an assessment or reducing the refund or otherwise increasing the liability of the person, an intimation to this effect shall be sent to the person electronically by the Centre and reply of the person shall be furnished through electronic mode only.
(iv) Where the rectification order results in a demand of tax, the order under section 154 of the Act passed by the Centre shall be deemed to be a notice of demand under section 156 of the Income-tax Act.
5. The provisions of section 245 of the Act shall apply to the returns covered under the Centralised Processing of Returns Scheme, 2011 subject to the following, namely:-
The set-off of refund, if any, arising from the processing of a return, against tax remaining payable shall be done by using the details of outstanding tax demand in respect of the person as uploaded onto the system of the Centre by the Assessing Officer.
6. (i) Where a return is processed at the Centre, the appeal proceedings relating to the processing of the return shall lie with Commissioner of Income-tax (Appeals) having jurisdiction over the Assessing Officer and any reference to the Commissioner of Income-tax (Appeals) in any communication from the Centre shall mean such jurisdiction of the said Commissioner.
(ii) Remand reports, giving effect to appellate order and any other reports to be furnished before the Commissioner of Income-tax (Appeals) shall be submitted by the Assessing Officer having jurisdiction as regards the person.
7. The provisions of section 282 of the Act shall apply to all returns received under the Centralised Processing of Returns Scheme, 2011 subject to the following, namely : -
(i) The service of a notice or order or any other communication by the Centre may be made by :
(a) sending it by post;
(b) delivering or transmitting its copy thereof, to the person's e-mail address by the Centre's e-mail;
(c) placing its copy in the my account menu of the person on the official website for e-filing of returns; or
(d) any of the modes mentioned in section 282(1) of the Income-tax Act.
(ii) The date of posting of any such communication on the website, e-mail or other electronic medium shall be deemed to be the date of service.
(iii) The intimation, orders and notices shall be computer generated and need not carry physical signature of the person signing it.
8. The Director General may specify procedures and processes from time to time for effective functioning of the Centre in an automated and mechanised environment, including specifying the procedure and processes in respect of the following :-
(a) receipt and processing of electronic rectification applications in the Centre;
(b) the address or place, the mode and the period or the extended period within which the acknowledgement in Form ITR-V shall be accepted;
(c) validating any software used for e-filing the return;
(d) call centers to answer queries and provide taxpayer services which may include outbound calls to persons requesting for clarification to assist in the processing of their returns of income; and
(e) managing tax administration functions such as receipt, scanning, data entry, processing, issue of refunds, storage and retrieval of income-tax returns and documents in a centralized manner or receipt of paper documents through authorised intermediaries.
AST INSTRUCTION NO.114 [F.NO.AST/DIT(S)-III/INST.NO.114/32/2012-13], DATED 26-3-2013
Kindly refer to the above.
2. Representations from field formations have been received intimating that owing to the delays in PAN Migration, PAN de-duplication and restoration, certain cases remain to be processed. However, AST does not permit these cases to be processed. Therefore, with the Board's approval, the facility of "Online TMS" is extended for the cases time barring on 31-3-2013. The path for the same is AST → TMS → Processing of New Returns (Online TMS).
3. This software is capable of handling the issues relating to PAN transfer/de-duplication/restoration which prevented processing of the returns in AST. The key features of the software are as under :
(a)
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The returns can be entered by AO having return of income, although the PAN is lying in some other jurisdiction.
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(b)
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The returns with PAN out of Jurisdiction, deleted PAN, PAN under de-duplication, PAN under restoration etc. can be processed on this System.
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(c)
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The AO having return of income can process returns till the command for integration of this data to AST is given by the jurisdictional AO. Once data has been integrated with AST, all future actions can be performed by the AO having PAN jurisdiction.
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Therefore, Online TMS is allowed to the following categories:
(i)
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PAN under migration
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(ii)
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PAN is deleted in de-duplication process
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(iii)
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PAN is under de-duplication or restoration.
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4. No processing of any sort will be allowed in respect of invalid PANs or if the PAN is not available or if Name in PAN database does not match with Return name. Due care needs to be taken while accepting such returns. Alternatively, the AO should initiate the communication with Assessee based on the address given in the return for quoting correct PAN and proceed under AST or online TMS, as the case may be. Under no circumstances, processing on standalone except select cases under DGIT(Int.Tax.)/offline TMS is permitted by the Board.
5. The procedure has been enumerated in the user manual available on itaxnet and ITD. The functionality will be available till 31-3-2013. This instruction may be brought to the knowledge of all field officers working in your charge.
C. Instruction
Income-tax Act
Section 143 of the Income-tax Act, 1961 - Assessment - Processing of returns for assessment year 2007-08 - Steps to clear the backlog
INSTRUCTION NO. 12/2008, DATED 5-9-2008
A review of CAP-II statements for June and July 2008 shows a large pendency of returns for assessment year 2007-08 in almost all CCIT Regions. The Board had earlier kept a target of 4-6 months for processing of returns. The criteria for matching claims for granting TDS certificates were relaxed in June 2006 in order to expedite the processing of pending returns and necessary instruction in this regard was issued vide instruction No. 6/2008 dated 18th June, 2008. However, the number of returns processed has not shown any significant improvement. A large number of electronic returns for assessment year 2007-08 as also refund returns are still pending for processing. The Board is concerned about a slow pace of progress in this regard. In order to speed up the processing of pending returns for assessment year 2007-08, it has been decided to adopt the following strategy :—
(1) All pending returns for assessment year 2007-08 involving refund claims (including electronic returns with refund claims) must be processed on priority basis by 30th September, 2008. Where any scrutiny assessment is pending in these cases, refund should be issued only after completion of the scrutiny assessment.
(2) For processing electronic returns involving refund claims, TDS data supplied by DGIT (Systems) on CDs along with AST instructions 68 may be utilized.
(3) Refund returns involving inter-RCC migration of PAN may be processed on TMS.
(4) Since data of electronic returns is already on the system, once this is acquired into the RCC data base, it will become part of the selection process under CASS. Therefore, electronic returns for assessment year 2007-08 not involving refund claims can be taken up for processing after 30th September. However, it has to be ensured that all such returns are acquired and incorporated into RCC data base before the next round of CASS is run.
(5) Returns in forms ITR-4 and 5 filed in paper mode by business assessees and not covered by section 44AB of the Income-tax Act, 1961 should be taken up for processing on AST at the stations on network, on priority basis at the earliest before next round of selection through CASS.
(6) Salary returns for assessment year 2007-08 in which there is no refund or demand and the TDS claim is below Rs. 5 lakh, may be given the last priority for processing.
<>Clues for an independent Study:
Provided above is a synopsys of material requiring a conscious note to be made; these concern the ongoing deliberations re the TDS woes (or blues !), largely faced by inter alia the 'salaried' class , numbering lakhs, constituting a significant section of the honest taxpayers.
As one views it, the Delhi HC has fairly gone into and insightfully dealt with the enormity of the injustice the deductees have been involuntarily confronted with, thanks to the nationwide electronic network (computerization) and the CPC set up. However, if critically studied, it appears that, the mess up of the TDS regime as spoken of and covered in the court verdict is primarily attributable to a fatal mistake made by the tax administration in using the CPC for processing of, not only the e'filed returns, but also the manually filed returns with no 26 AS online. In one's conviction, in doing so, the scheme of the applicable newly introduced new provisions for accomplishing the computerised system of tax administration in the realm of TDS regime have been unethically departed from, unwittingly or otherwise.
More importantly, it is noteworthy, in the proceedings before the HC, one very vital and clinching aspect that ought to have been raised and dealt with, but as is observed, has been strikingly over sighted. That has some thing to do with the implications of, bsides section 200A, the ageold mandate in section 205.
It is observed that,the article of Delhi CA, Muralidharan publ-ished in BL, besides in the HC Order, those areas hinted out above, albeit being of every relevance, do not seem to have been focussed on or dwelt upon.
Hence, it might be worthwhile to have a useful interaction, aimed at an intelligent deliberation and incisive introspection, in an attempt for having one's own independent thoughts shared and clarified for the benefit of the harassed deductees at their wits' end.
Other Cir. >>>
Useful Miscellania » CBDT Instruction On Grant Of TDS Credit For ...
www.itatonline.org/.../cbdt-instruction-on-processing-of-returns-for-...May 26, 2012 – 01/2012 issued on 2nd February, 2012 on the subject above with immediate effect. ... CBDT Circular On Procedure For Refund Of Excess TDS Deducted/ ... Otherwise these ridiculous instructions are of no use for mitigating ...TAX 24x7: CBDT wakes up: Issues Circular 4/2012 allowing AO's to ...
tax24x7.blogspot.com/2012/.../cbdt-wakes-up-issues-circular-42012....Jun 22, 2012 – CBDT has issued circular 4/2012 on 20/06/2012 allowing Assessing Officers ... No penalty u/s 271(1)(c) for additions to normal income where ...- [PDF]
CBDT CIRCULAR NO- 01!2012 - Webtel
www.webtel.in/image/circular1.pdfFile Format: PDF/Adobe Acrobat - Quick View
EiEIt5@. P.1. CBDT CIRCULAR NO- 01!2012. F'.No. 27613412011 -iT(B) ... (“the Rules“) provides for furnishing ef certificate of ten Qeguctioh at ecurce (T08) by ...
Prerogative Writs
http://en.wikipedia.org/wiki/Prerogative_writ
@ India[edit]
The declaration of fundamental rights would be meaningless unless these rights can be enforced at the instance of the persons on whom they are conferred. The Constitution itself has laid down the following provisions for the enforcement of the fundamental rights. (a) Any act of the executive or of the Legislature which takes away or abridges the fundamental rights shall be void and the courts are empowered to declare such act as void. (Article 13) (b) The Supreme Court and the High Courts are empowered to issue writs for the enforcement of fundamental rights against any authority of the State. Article 12 has defined "State" to include the Government and Parliament of India, and the Government and Legislature of the States, and all local or other authorities within the territory of India or under the control of the Government of India. The expression, "other authorities" has been interpreted to cover even business organisations like LIC and therefore such organisations also are amenable to the writ jurisdiction of the courts. (c) A proceeding under Article 32 is described as a constitutional remedy and the right to bring such proceedings before the Supreme Court is itself a fundamental right.
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