Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Penalty against a customs broker failed where the import dispute was treated as an interpretational classification issue and the importer had already been exonerated for absence of mala fide intent. On those facts, a broker who merely filed Bills of Entry on the importer's instructions could not be said to have abetted evasion, and the ingredients for penalty based on false declaration were not made out. The Tribunal also held that the objection on invocation of the larger period would apply equally to the appellants. The penalties under Sections 112(a) and 114AA were deleted and the appeals were allowed.
Penalty against a customs broker failed where the import dispute was treated as an interpretational classification issue and the importer had already been exonerated for absence of mala fide intent. On those facts, a broker who merely filed Bills of Entry on the importer's instructions could not be said to have abetted evasion, and the ingredients for penalty based on false declaration were not made out. The Tribunal also held that the objection on invocation of the larger period would apply equally to the appellants. The penalties under Sections 112(a) and 114AA were deleted and the appeals were allowed.
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