Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Deemed concealment under Explanation 3 to section 271(1)(c) may apply where a taxpayer files a return only in response to a notice under section 148 and lacks reasonable cause for not filing the original return. However, the tax sought to be evaded must be computed under clause (c) of Explanation 4 after reducing tax deducted at source before the section 148 notice. Where pre-notice tax deducted at source exceeds the final assessed tax liability, no tax is sought to be evaded and penalty under section 271(1)(c) is not leviable. The penalty was deleted.
Deemed concealment under Explanation 3 to section 271(1)(c) may apply where a taxpayer files a return only in response to a notice under section 148 and lacks reasonable cause for not filing the original return. However, the tax sought to be evaded must be computed under clause (c) of Explanation 4 after reducing tax deducted at source before the section 148 notice. Where pre-notice tax deducted at source exceeds the final assessed tax liability, no tax is sought to be evaded and penalty under section 271(1)(c) is not leviable. The penalty was deleted.
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