Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
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Section 270A requires a specific statutory charge before enhanced penalty for misreporting can be imposed. Under-reporting is distinct from under-reporting resulting from misreporting, and misreporting must fall within one of the exhaustively listed instances in section 270A(9)(a) to (g). Where the charge shifts during proceedings and the applicable statutory limb is not identified, the defect is non-curable and vitiates the penalty proceedings. Enhanced penalty for alleged misreporting was therefore deleted because the precise charge and statutory basis were not specified.
Section 270A requires a specific statutory charge before enhanced penalty for misreporting can be imposed. Under-reporting is distinct from under-reporting resulting from misreporting, and misreporting must fall within one of the exhaustively listed instances in section 270A(9)(a) to (g). Where the charge shifts during proceedings and the applicable statutory limb is not identified, the defect is non-curable and vitiates the penalty proceedings. Enhanced penalty for alleged misreporting was therefore deleted because the precise charge and statutory basis were not specified.
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