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...
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Penalty for misreporting under section 270A requires the assessing authority to identify the precise limb in section 270A(9) and explain how the additions satisfy that clause. A mere ad hoc disallowance of labour or loading and unloading charges, or a disallowance based on alleged non-deduction of tax at source, does not by itself establish misreporting of income. The text also notes that email-only appellate notices, when the assessee had opted for another mode, do not justify an adverse inference from non-appearance. On that reasoning, the penalty was deleted.
Penalty for misreporting under section 270A requires the assessing authority to identify the precise limb in section 270A(9) and explain how the additions satisfy that clause. A mere ad hoc disallowance of labour or loading and unloading charges, or a disallowance based on alleged non-deduction of tax at source, does not by itself establish misreporting of income. The text also notes that email-only appellate notices, when the assessee had opted for another mode, do not justify an adverse inference from non-appearance. On that reasoning, the penalty was deleted.
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