Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
Tax collection at source on purchases removes duplicate withholding obligation, while trade-creditor evidence requires verification before unexplained...
Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
Cash deposits fully disclosed through a revised computation during assessment, with tax paid and the computation accepted, may constitute under-reporting rather than misreporting where the assessment does not identify any statutory ingredient of misreporting. Assessment of the deposits as income from other sources does not itself establish misreporting. On that classification, immunity from penalty for under-reporting is available, and penalty imposed for misreporting is unjustified. The appeal was allowed.
Cash deposits fully disclosed through a revised computation during assessment, with tax paid and the computation accepted, may constitute under-reporting rather than misreporting where the assessment does not identify any statutory ingredient of misreporting. Assessment of the deposits as income from other sources does not itself establish misreporting. On that classification, immunity from penalty for under-reporting is available, and penalty imposed for misreporting is unjustified. The appeal was allowed.
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