Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
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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