Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Penalty under section 271AAB requires undisclosed income as exhaustively defined in its Explanation; a surrender made during a search does not alone establish that statutory character. Land and other advances represent application or outflow of funds rather than an unrecorded income inflow, and deeming provisions for unexplained investments cannot be automatically applied to this self-contained penal provision. Uncorroborated diary notings without verifiable particulars cannot independently prove real transactions or undisclosed income. As the amount was accepted as current-year business income without a requisite finding of undisclosed income, deletion of the penalty on the surrendered advances was sustained.
Penalty under section 271AAB requires undisclosed income as exhaustively defined in its Explanation; a surrender made during a search does not alone establish that statutory character. Land and other advances represent application or outflow of funds rather than an unrecorded income inflow, and deeming provisions for unexplained investments cannot be automatically applied to this self-contained penal provision. Uncorroborated diary notings without verifiable particulars cannot independently prove real transactions or undisclosed income. As the amount was accepted as current-year business income without a requisite finding of undisclosed income, deletion of the penalty on the surrendered advances was sustained.
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