Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
