Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...
Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...
Section 270A distinguishes under-reporting from misreporting, with different statutory consequences. For a misreporting penalty, the Assessing Officer must specify the precise applicable clause in both the notice and penalty order; a generic reference leaves the taxpayer unaware of the charge and invalidates the proceedings. Where divergent Tribunal views support the taxpayer's adopted legal position on interest from enhanced compensation, that position cannot by itself amount to misreporting. The penalty for alleged misreporting was therefore deleted and the appeal allowed.
Section 270A distinguishes under-reporting from misreporting, with different statutory consequences. For a misreporting penalty, the Assessing Officer must specify the precise applicable clause in both the notice and penalty order; a generic reference leaves the taxpayer unaware of the charge and invalidates the proceedings. Where divergent Tribunal views support the taxpayer's adopted legal position on interest from enhanced compensation, that position cannot by itself amount to misreporting. The penalty for alleged misreporting was therefore deleted and the appeal allowed.
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