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...
Penalty for failure to furnish a tax audit report was deleted where consistent past and subsequent treatment of bank interest as income from other sources supported a bona fide belief that the audit requirement was not attracted. The assessee had disclosed the interest uniformly in earlier and later years, and that treatment had been accepted in section 143(1) intimations. As the Revenue produced no material of deliberate or conscious default, the failure was treated as covered by reasonable cause, making the penalty unsustainable.
Penalty for failure to furnish a tax audit report was deleted where consistent past and subsequent treatment of bank interest as income from other sources supported a bona fide belief that the audit requirement was not attracted. The assessee had disclosed the interest uniformly in earlier and later years, and that treatment had been accepted in section 143(1) intimations. As the Revenue produced no material of deliberate or conscious default, the failure was treated as covered by reasonable cause, making the penalty unsustainable.
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