Sunday, 31 December 2023

Adjustment of income tax refund against demand:

 

1.     Section 245 of the Income Tax Act mandates the tax department to send an intimation to the taxpayer before implementing any adjustments. This intimation includes details such as the amount of refund owed, the outstanding tax demand, and the proposed adjustment. 

 

2.     The taxpayer is granted a 30-day window to respond to the intimation, either agreeing or disagreeing with the proposed adjustment. If the taxpayer concurs, the department proceeds to offset the refund against the demand and issues any remaining refund. In cases of disagreement, where the Assessing Officer finds the Assessee's claim untrue based on available information and explanations, the department may still adjust the refund.

 

3.     Preceding the commencement of the Financial Year 2023-24, Section 241A empowers the Assessing Officer to withhold a refund if it becomes due to an Assessee after ITR processing, but assessment or reassessment proceedings are pending. This withholding, intended to prevent adverse impacts on government tax revenue, requires prior approval from the Principal Commissioner or Commissioner. The provision is applicable to assessment years from 2017-18 onward.

 

4.     The Finance Act of 2023 amalgamated Section 241A with Section 245. The amended Section 245 now allows the Assessing Officer to withhold a refund if, despite a partial set-off or no set-off, a refund is due to a person while assessment or reassessment proceedings are pending. This withholding requires approval from the Principal Commissioner or Commissioner.

 

5.     Amendments to Section 244A stipulate that interest on income tax refunds will not be provided for the period between the date of withholding the refund and the completion of assessment or reassessment

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