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 270A for under-reporting of income may be excluded where a bona fide computational error explains the reduction of a returned loss and all material facts were disclosed. The notes describe an inadvertent double deduction of exempt partnership-firm profit in Schedule BP, although the amount had already been disclosed in Schedule EI and reflected in the balance sheet. Acceptance of recomputation, supported by a Chartered Accountant's affidavit, and the absence of proof that the explanation was false supported deletion of the penalty. Repetition of the error in a revised return was not, by itself, treated as conclusive evidence of misreporting or inaccurate particulars.
Penalty under section 270A for under-reporting of income may be excluded where a bona fide computational error explains the reduction of a returned loss and all material facts were disclosed. The notes describe an inadvertent double deduction of exempt partnership-firm profit in Schedule BP, although the amount had already been disclosed in Schedule EI and reflected in the balance sheet. Acceptance of recomputation, supported by a Chartered Accountant's affidavit, and the absence of proof that the explanation was false supported deletion of the penalty. Repetition of the error in a revised return was not, by itself, treated as conclusive evidence of misreporting or inaccurate particulars.
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