Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
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.
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