Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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Penalty proceedings for concealment require the Assessing Officer to reach satisfaction during assessment; a later notice cannot replace that jurisdictional requirement. Section 271(1) uses "may", preserving discretion and preventing automatic penalty merely because additional income is declared in returns filed under section 148. The deeming fiction in section 271(1B) applies strictly only where an addition or disallowance is made and the assessment order contains a clear direction to initiate penalty. A statement that proceedings "will be initiated separately" is only a future intention. Explanation 5A may deem concealment in specified circumstances but cannot cure invalid initiation or make penalty automatic. Penalties were deleted, while their merits remained open.
Penalty proceedings for concealment require the Assessing Officer to reach satisfaction during assessment; a later notice cannot replace that jurisdictional requirement. Section 271(1) uses "may", preserving discretion and preventing automatic penalty merely because additional income is declared in returns filed under section 148. The deeming fiction in section 271(1B) applies strictly only where an addition or disallowance is made and the assessment order contains a clear direction to initiate penalty. A statement that proceedings "will be initiated separately" is only a future intention. Explanation 5A may deem concealment in specified circumstances but cannot cure invalid initiation or make penalty automatic. Penalties were deleted, while their merits remained open.
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