Interest and penalty for undisclosed income: delayed or absent returns trigger interest and discretionary penalties with procedural limits. The provision imposes interest on tax attributable to undisclosed income for delayed or absent returns related to searches or requisitions and authorises imposition of a penalty between not less than and up to a specified multiple of the tax determined on such undisclosed income, subject to exceptions where a return is filed and tax paid or offered, and subject to procedural safeguards and limitation rules including opportunity to be heard, approval requirements for larger penalties, exclusion of certain historical searches, and exclusion of specified periods when computing limitation.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Interest and penalty for undisclosed income: delayed or absent returns trigger interest and discretionary penalties with procedural limits.
The provision imposes interest on tax attributable to undisclosed income for delayed or absent returns related to searches or requisitions and authorises imposition of a penalty between not less than and up to a specified multiple of the tax determined on such undisclosed income, subject to exceptions where a return is filed and tax paid or offered, and subject to procedural safeguards and limitation rules including opportunity to be heard, approval requirements for larger penalties, exclusion of certain historical searches, and exclusion of specified periods when computing limitation.
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