Sufficient cause for delayed revenue income-tax appeals requires bona fides, due diligence and a credible explanation; otherwise limitation bars appea...
Inverted-duty-structure refunds remain available for unchanged-rate apparel supplies despite trader status and require tax-period-specific computation...
Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
Penalty under section 271(1)(c) cannot rest on a disallowance of business interest on secured promissory notes once the underlying quantum disallowance has been reversed. Interest on those notes was treated as incurred for business purposes and therefore not deductible only on an unsustainable basis. The Tribunal's deletion of penalty was upheld because the issue was initially debatable and the quantum position later attained finality. With no surviving basis for the disallowance, the penalty could not continue, and the Revenue's appeals were dismissed.
Penalty under section 271(1)(c) cannot rest on a disallowance of business interest on secured promissory notes once the underlying quantum disallowance has been reversed. Interest on those notes was treated as incurred for business purposes and therefore not deductible only on an unsustainable basis. The Tribunal's deletion of penalty was upheld because the issue was initially debatable and the quantum position later attained finality. With no surviving basis for the disallowance, the penalty could not continue, and the Revenue's appeals were dismissed.
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