Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The proviso to Section 276CC bars prosecution for failure to furnish an income-tax return where tax payable on total income determined on regular assessment, after reducing advance tax and tax deducted at source, does not exceed the prescribed threshold. Where no tax remains due and tax deducted at source exceeds the assessed liability, delayed filing cannot sustain prosecution. On these facts, continuation of criminal proceedings constituted an abuse of process and the prosecution was quashed.
The proviso to Section 276CC bars prosecution for failure to furnish an income-tax return where tax payable on total income determined on regular assessment, after reducing advance tax and tax deducted at source, does not exceed the prescribed threshold. Where no tax remains due and tax deducted at source exceeds the assessed liability, delayed filing cannot sustain prosecution. On these facts, continuation of criminal proceedings constituted an abuse of process and the prosecution was quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
