Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Section 271AAB imposes penalty only where the amount falls within its exhaustive definition of undisclosed income; a surrender during search proceedings alone is insufficient. Diary entries recording advances indicate an outflow or application of funds, rather than unreported income, unless a corresponding undisclosed asset or source is established. Deeming rules for unexplained sums do not automatically apply to this self-contained penalty provision. The Assessing Officer must specifically establish that the amount was found in, or resulted from, the search as undisclosed income. Penalty on surrendered advances reflected in vague diary notings was therefore deleted.
Section 271AAB imposes penalty only where the amount falls within its exhaustive definition of undisclosed income; a surrender during search proceedings alone is insufficient. Diary entries recording advances indicate an outflow or application of funds, rather than unreported income, unless a corresponding undisclosed asset or source is established. Deeming rules for unexplained sums do not automatically apply to this self-contained penalty provision. The Assessing Officer must specifically establish that the amount was found in, or resulted from, the search as undisclosed income. Penalty on surrendered advances reflected in vague diary notings was therefore deleted.
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