Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
Misreporting of income under section 270A is not established merely because a donation deduction claimed under section 80GGC was disclosed in the return and later disallowed or withdrawn in a reassessment return. Misreporting requires material indicating deliberate furnishing of inaccurate particulars, false evidence, suppression, or misrepresentation. Where the taxpayer fulfils the substantive conditions for immunity under section 270AA(1), penalty protection applies. On these principles, the penalty imposed for misreporting was deleted and the appeal was allowed.
Misreporting of income under section 270A is not established merely because a donation deduction claimed under section 80GGC was disclosed in the return and later disallowed or withdrawn in a reassessment return. Misreporting requires material indicating deliberate furnishing of inaccurate particulars, false evidence, suppression, or misrepresentation. Where the taxpayer fulfils the substantive conditions for immunity under section 270AA(1), penalty protection applies. On these principles, the penalty imposed for misreporting was deleted and the appeal was allowed.
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