Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
Interest on undisclosed foreign income under the Black Money Act requires non-disclosure of the foreign source in the return; estimation or variation of income from an already disclosed foreign account does not satisfy that condition. Timely filing also prevents interest under the incorporated late-filing computation provisions. Advance-tax interest cannot be imposed without clear statutory language establishing the liability and machinery, and incorporated advance-tax provisions include exemptions for resident senior citizens without business income. Where rectification adds interest linked to the underlying foreign-income addition, the original and rectified orders operate as a composite order, permitting a limited challenge to the connected quantum addition; that issue requires merits consideration.
Interest on undisclosed foreign income under the Black Money Act requires non-disclosure of the foreign source in the return; estimation or variation of income from an already disclosed foreign account does not satisfy that condition. Timely filing also prevents interest under the incorporated late-filing computation provisions. Advance-tax interest cannot be imposed without clear statutory language establishing the liability and machinery, and incorporated advance-tax provisions include exemptions for resident senior citizens without business income. Where rectification adds interest linked to the underlying foreign-income addition, the original and rectified orders operate as a composite order, permitting a limited challenge to the connected quantum addition; that issue requires merits consideration.
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