Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
Penalty for misreporting of income under section 270A could not be sustained where the assessee had disclosed the interest income and the dispute concerned only eligibility for deduction under section 80P(2)(d). The Tribunal held that penalty proceedings are distinct from assessment proceedings, and an addition or disallowance by itself does not establish misreporting; the Assessing Officer must show that the case falls within a specific statutory category. The assessee's explanation that incorrect PAN status caused a technical difficulty was found bona fide, and there was no material of false particulars or suppression. The penalty also failed because the notice mentioned only under-reporting, while the final levy was for under-reporting due to misreporting without specifying the relevant charge.
Penalty for misreporting of income under section 270A could not be sustained where the assessee had disclosed the interest income and the dispute concerned only eligibility for deduction under section 80P(2)(d). The Tribunal held that penalty proceedings are distinct from assessment proceedings, and an addition or disallowance by itself does not establish misreporting; the Assessing Officer must show that the case falls within a specific statutory category. The assessee's explanation that incorrect PAN status caused a technical difficulty was found bona fide, and there was no material of false particulars or suppression. The penalty also failed because the notice mentioned only under-reporting, while the final levy was for under-reporting due to misreporting without specifying the relevant charge.
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