Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
A bona fide deduction claim under section 80P(2)(a)(i), previously accepted in scrutiny assessment and rectification proceedings, was not treated as under-reported income in the stated circumstances. The notes state that section 270A(1) uses "may", requiring consideration of the full circumstances rather than automatic penalty. They further state that a penalty notice and order referring only generally to section 270A, without specifying the applicable sub-clause or limb, cannot sustain the penalty. The reported conclusion is that the penalty for under-reporting was deleted.
A bona fide deduction claim under section 80P(2)(a)(i), previously accepted in scrutiny assessment and rectification proceedings, was not treated as under-reported income in the stated circumstances. The notes state that section 270A(1) uses "may", requiring consideration of the full circumstances rather than automatic penalty. They further state that a penalty notice and order referring only generally to section 270A, without specifying the applicable sub-clause or limb, cannot sustain the penalty. The reported conclusion is that the penalty for under-reporting was deleted.
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