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...
Penalty for under-reporting attributable to misreporting applies where inadmissible deductions are claimed against interest income from nationalised banks and dividend income. The statutory protection based on a bona fide explanation is confined to under-reported income and does not extend to under-reporting resulting from misreporting. Once the Assessing Officer classifies the conduct as misreporting and applies the corresponding charge, penalty follows at the prescribed rate. Payment of tax and interest after disallowance in scrutiny assessment, while penalty proceedings remain pending, does not constitute voluntary disclosure or establish a bona fide mistake. The penalty for misreporting was sustained and the appeal dismissed.
Penalty for under-reporting attributable to misreporting applies where inadmissible deductions are claimed against interest income from nationalised banks and dividend income. The statutory protection based on a bona fide explanation is confined to under-reported income and does not extend to under-reporting resulting from misreporting. Once the Assessing Officer classifies the conduct as misreporting and applies the corresponding charge, penalty follows at the prescribed rate. Payment of tax and interest after disallowance in scrutiny assessment, while penalty proceedings remain pending, does not constitute voluntary disclosure or establish a bona fide mistake. The penalty for misreporting was sustained and the appeal dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
