Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Pre-existing disputes over outcome-based professional fees can bar Section 9 insolvency proceedings where contractual entitlement requires investigati...
Corresponding scheduled offences preserve money-laundering jurisdiction despite repeal of the central corruption provision where conduct remains cover...
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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TaxTMI 
TaxTMI 
of 4897 
