Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
Penalty for acceptance of cash loans was held unsustainable where the assessment order under section 143(3) accepted the returned income but did not record satisfaction for initiating proceedings under section 271D. Applying the principle in Jai Laxmi Rice Mills, the Tribunal treated the absence of recorded satisfaction in the assessment order as fatal to penalty initiation and directed deletion of the penalty.
Penalty for acceptance of cash loans was held unsustainable where the assessment order under section 143(3) accepted the returned income but did not record satisfaction for initiating proceedings under section 271D. Applying the principle in Jai Laxmi Rice Mills, the Tribunal treated the absence of recorded satisfaction in the assessment order as fatal to penalty initiation and directed deletion of the penalty.
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