Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Release of buyback escrow under the exceptions to Regulation 15B(8) does not bar an independent fraud inquiry under the PFUTP Regulations, because the provision concerns escrow forfeiture or release rather than whether fraud occurred. Internal departmental file notings remain non-binding unless converted into and communicated as a final decision of the competent authority. Fraud must be proved on a balance of probabilities through objective, corroborative circumstances, including trading patterns, contemporaneous records and attributable conduct. The fraud allegation was remanded for fresh adjudication after examination of trading-data discrepancies, inconsistent investigation reports and corroborative material; the appeals were partly allowed.
Release of buyback escrow under the exceptions to Regulation 15B(8) does not bar an independent fraud inquiry under the PFUTP Regulations, because the provision concerns escrow forfeiture or release rather than whether fraud occurred. Internal departmental file notings remain non-binding unless converted into and communicated as a final decision of the competent authority. Fraud must be proved on a balance of probabilities through objective, corroborative circumstances, including trading patterns, contemporaneous records and attributable conduct. The fraud allegation was remanded for fresh adjudication after examination of trading-data discrepancies, inconsistent investigation reports and corroborative material; the appeals were partly allowed.
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TaxTMI 
TaxTMI 
of 4886 
