Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Penalty notices under section 271(1)(c) must clearly identify whether the charge concerns concealment of income or furnishing inaccurate particulars. The two limbs are independent and may require different explanations and treatment; therefore, a notice retaining both alternatives without specifying the applicable limb denies the assessee a proper opportunity to defend. Recording satisfaction to initiate penalty proceedings does not cure this defect. Applying this principle, the High Court treated the defective notice as invalid, upheld deletion of the penalty, and dismissed the revenue's appeal.
Penalty notices under section 271(1)(c) must clearly identify whether the charge concerns concealment of income or furnishing inaccurate particulars. The two limbs are independent and may require different explanations and treatment; therefore, a notice retaining both alternatives without specifying the applicable limb denies the assessee a proper opportunity to defend. Recording satisfaction to initiate penalty proceedings does not cure this defect. Applying this principle, the High Court treated the defective notice as invalid, upheld deletion of the penalty, and dismissed the revenue's appeal.
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