Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Pre-existing disputes over outcome-based professional fees can bar Section 9 insolvency proceedings where contractual entitlement requires investigati...
Corresponding scheduled offences preserve money-laundering jurisdiction despite repeal of the central corruption provision where conduct remains cover...
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Return-processing adjustments to a charitable accumulation claim require compliance with the first proviso to section 143(1A), including an opportunity before the adjustment is made. Non-compliance vitiated the adjustment. Where an assessee's accumulated amount was incorrectly reported through an inadvertent return-form error, supported by an indemnity bond and a revised Form 10B, rectification required substantive consideration rather than rejection solely on a technical basis. The processing and rectification orders were set aside and remanded for consideration of the revised audit report, determination of correct income, and grant of admissible relief.
Return-processing adjustments to a charitable accumulation claim require compliance with the first proviso to section 143(1A), including an opportunity before the adjustment is made. Non-compliance vitiated the adjustment. Where an assessee's accumulated amount was incorrectly reported through an inadvertent return-form error, supported by an indemnity bond and a revised Form 10B, rectification required substantive consideration rather than rejection solely on a technical basis. The processing and rectification orders were set aside and remanded for consideration of the revised audit report, determination of correct income, and grant of admissible relief.
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