Relaxation of time limit for processing of returns of income filed electronically which were incorrectly invalidated by CPC

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DTAA - Virtual Service Permanent Establishment (VSPE) cannot be read into provisions of DTAA, as Article 5 of India-UK Treaty makes no provision for VSPE: ITAT (See Breaking News)

I-T - Assessment order passed after expiry of time limit stipulated in section 153 is barred by limitation and is invalid in law, even if it adheres to one-month timeline within section 144C(13): ITAT (See Breaking News)

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I-T - Competent Authority shall issue Nil Tax Withholding Certificate within stipulated time, if delay will practically render assessee's case infructuous and will be of no avail as F.Y will be over: HC (See Breaking News)

I-T - Final assessment order passed beyond time limit prescribed u/s 153 is barred by limitation and is invalid, even if internal timelines within Sec 144C procedure were adhered to: ITAT (See Breaking News)

DTAA - Since payment for standard transponder services does not involve any secret process, it is not taxable as royalty in India under Treaty: ITAT (See Breaking News)

INTL - Expenditure incurred wholly & exclusively for business purpose cannot be disallowed merely because it was not necessary or profitable: ITAT (See Breaking News)

I-T - Section 144C and Section 153 are not mutually exclusive but are mutually inclusive and must be read harmoniously: ITAT (See Breaking News)

TP - Mere reclassification of Compulsorily Convertible Debentures into equity & debt components under Ind-AS does not alter their intrinsic nature as debt instruments until actual conversion: ITAT (See Breaking News)

TP - Addition framed TPO invalid where transaction in question is covered by binding Advance Pricing Agreement between assessee & CBDT as per Section 92CC: ITAT (See Breaking News)

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Relaxation of time limit for processing of returns of income filed electronically which were incorrectly invalidated by CPC By TII News Service Jul 28, 2025 , New Delhi
Untitled Document GOVERNMENT OF INDIA MINISTRY OF FINANCE DEPARTMENT OF REVENUE CENTRAL BOARD OF DIRECT TAXES NEW DELHI CIRCULAR NO 10/2025; Dated: July 28, 2025 Order u/s 119 of the Income-tax Act, 1961 Subject: Relaxation of time limit for processing of returns of income filed electronically which were incorrectly invalidated by CPC-reg. It has been brought to the notice of Central Board of Direct Taxes ('the Board') that CPC-Bengaluru (CPC) has received grievances regarding erroneous invalidation, due to various technical reasons, while processing the returns filed electronically for different assessment years. The time period for processing these returns has lapsed, latest being 31.12.2024 for AY 2023-24. Therefore, these returns need to be validated and processed as per law. 2. The matter has been considered by the Board and it has been decided to relax the time-frame prescribed in second proviso to sub-section (1) of section 143 of the Income-tax Act, 1961 (the Act) in exercise of its powers under section 119 of the Act. The Board hereby directs that returns of income filed electronically upto 31.03.2024 which have been erroneously invalidated by CPC shall now be processed. The intimation under sub-section (1) of section 143 of the Act in respect of processing of such returns shall be sent to the assessees concerned by 31.03.2026. 3. All subsequent effects under the Act, including issue of refund along with interest as applicable, shall also follow in these cases. In those cases where PAN-Aadhaar linkage is not found, refund of any amount of tax or part thereof, due under the provisions of the Act shall not be made as laid down in Circular No.03/2023 dated 28.03.2023 vide F.No.370142/14/2022-TPL. 4. This may be brought to the notice of all for necessary compliance. [F. No.225/30/2025/ITA-II] (Dr Castro Jayaprakash T) Under Secretary to the Government of India

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