Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Penalty under section 271(1)(c) could not survive once the related interest disallowance under section 36(1)(iii) had already been deleted in the quantum appeal, because the basis for the penalty no longer existed. On the subsidy issue, the Tribunal treated the capital-versus-revenue characterisation of the grant as a debatable question and held that such a disputed classification did not establish concealment or furnishing of inaccurate particulars. The penalty was therefore deleted in full.
Penalty under section 271(1)(c) could not survive once the related interest disallowance under section 36(1)(iii) had already been deleted in the quantum appeal, because the basis for the penalty no longer existed. On the subsidy issue, the Tribunal treated the capital-versus-revenue characterisation of the grant as a debatable question and held that such a disputed classification did not establish concealment or furnishing of inaccurate particulars. The penalty was therefore deleted in full.
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