Qualcomm India Private Limited vs. Dy.CIT

Parties Involved

Facts Summary

Qualcomm India Private Limited had filed its return of income for the Financial Year 2021-22 on 24th November, 2022, declaring a total income of INR 1902,76,89,334 and a tax liability of INR 4,79,55,85,000. The assessee had received an intimation under section 143(1)(a) of the Income Tax Act, 1961 proposing adjustments for delay in the payment of employees' contribution to the Provident Fund amounting to INR 19,48,63,463. The assessee submitted its response against the proposed adjustments. Subsequently, the assessee received an intimation under section 143(1) of the Act for the subject Assessment Year wherein additions were made to the returned income, resulting in a demand of INR 5,07,14,260. The assessee filed a rectification application under section 154 of the Act. The assessee filed an appeal before the Learned Commissioner of Income Tax (Appeals), which was dismissed. The assessee then filed the present appeal.…

Legal Issues

• 1. Disallowance on account of delay in the payment of employees' contribution to the Provident Fund
• 2. Non-grant of TDS credit on interest on electricity deposit
• 3. Incorrect computation of interest under section 234C

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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