Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
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Penalty under section 270A could not be sustained where the assessee's revised-return claim rested on a bona fide, legally plausible POEM-based position under a then-nascent legal framework, and all material facts were disclosed. Rejection of the claim in assessment did not, by itself, establish misreporting, deliberate suppression, or contumacious conduct, so the case fell outside section 270A(9)(a). The Tribunal also held that assessment and penalty proceedings are separate and independent, and failure to appeal the quantum addition did not amount to acceptance of wrongdoing or justify penalty. The penalties were quashed and both appeals allowed.
Penalty under section 270A could not be sustained where the assessee's revised-return claim rested on a bona fide, legally plausible POEM-based position under a then-nascent legal framework, and all material facts were disclosed. Rejection of the claim in assessment did not, by itself, establish misreporting, deliberate suppression, or contumacious conduct, so the case fell outside section 270A(9)(a). The Tribunal also held that assessment and penalty proceedings are separate and independent, and failure to appeal the quantum addition did not amount to acceptance of wrongdoing or justify penalty. The penalties were quashed and both appeals allowed.
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