Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
A penalty notice for undisclosed income must specify the precise statutory limb or category of penalty invoked under section 271AAB. The note explains that failure to identify the applicable charge prevents the assessee from addressing the exact allegation and undermines a reasonable opportunity of defence. It states that a notice issued under section 274 read with section 271AAB without this specification is invalid, and that a penalty founded on such defective initiation is liable to be deleted.
A penalty notice for undisclosed income must specify the precise statutory limb or category of penalty invoked under section 271AAB. The note explains that failure to identify the applicable charge prevents the assessee from addressing the exact allegation and undermines a reasonable opportunity of defence. It states that a notice issued under section 274 read with section 271AAB without this specification is invalid, and that a penalty founded on such defective initiation is liable to be deleted.
Note: It is a system-generated summary and is for quick reference only.
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