Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
Penalty for misreporting under section 270A is addressed in relation to a disallowed deduction for political contributions under section 80GGC. Disallowance of a transparently disclosed claim, without material showing false evidence, suppression of facts or deliberate misrepresentation, does not by itself establish misreporting. Penalty proceedings must also identify the applicable limb of section 270A(9); failure to specify that statutory basis makes a penalty for under-reporting arising from misreporting unsustainable. On these grounds, the section 270A penalty was deleted, although other objections to the penalty proceedings failed.
Penalty for misreporting under section 270A is addressed in relation to a disallowed deduction for political contributions under section 80GGC. Disallowance of a transparently disclosed claim, without material showing false evidence, suppression of facts or deliberate misrepresentation, does not by itself establish misreporting. Penalty proceedings must also identify the applicable limb of section 270A(9); failure to specify that statutory basis makes a penalty for under-reporting arising from misreporting unsustainable. On these grounds, the section 270A penalty was deleted, although other objections to the penalty proceedings failed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
