Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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A bona fide excessive claim of donation exemption, made with full disclosure of facts, does not by itself establish under-reporting, misreporting, or inaccurate particulars for penalty purposes. The text distinguishes an unsustainable legal claim from furnishing inaccurate particulars and notes that penalty proceedings are separate from assessment proceedings. It also highlights that a penalty initiated for misreporting but levied for under-reporting lacked supporting material showing mala fides. Applying the principles that inadvertent human errors and incorrect legal claims do not attract penalty where facts are fully disclosed, the section 270A penalty was described as unsustainable and deleted.
A bona fide excessive claim of donation exemption, made with full disclosure of facts, does not by itself establish under-reporting, misreporting, or inaccurate particulars for penalty purposes. The text distinguishes an unsustainable legal claim from furnishing inaccurate particulars and notes that penalty proceedings are separate from assessment proceedings. It also highlights that a penalty initiated for misreporting but levied for under-reporting lacked supporting material showing mala fides. Applying the principles that inadvertent human errors and incorrect legal claims do not attract penalty where facts are fully disclosed, the section 270A penalty was described as unsustainable and deleted.
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