Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Social forestry expenditure requires activity-based...
Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additions do not increase tax.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Social forestry expenditure requires activity-based classification: costs of growing saplings through primary land operations are agricultural, while supervision of farmers' trees and coppice shoots without primary land operations are business or non-agricultural expenditure. Disallowance is therefore confined to the loss from agricultural sapling cultivation. For book-profit computation, only that restricted disallowed agricultural loss may be adjusted, rather than all amortised social forestry expenditure. Where normal-computation additions do not affect tax because liability is based on book profit, no tax is sought to be avoided and concealment penalty is not warranted. Penalty may nevertheless arise if concealed income increases book profit and the resulting minimum alternative tax.
Social forestry expenditure requires activity-based classification: costs of growing saplings through primary land operations are agricultural, while supervision of farmers' trees and coppice shoots without primary land operations are business or non-agricultural expenditure. Disallowance is therefore confined to the loss from agricultural sapling cultivation. For book-profit computation, only that restricted disallowed agricultural loss may be adjusted, rather than all amortised social forestry expenditure. Where normal-computation additions do not affect tax because liability is based on book profit, no tax is sought to be avoided and concealment penalty is not warranted. Penalty may nevertheless arise if concealed income increases book profit and the resulting minimum alternative tax.
Note: It is a system-generated summary and is for quick reference only.