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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Penalty for under-reported income is excluded where the taxpayer provides a bona fide explanation and fully discloses supporting material facts. Uploading audit records, paying relevant taxes before reassessment, and filing income accepted without additions supported cancellation under section 270A. Delayed tax-audit reporting does not attract penalty where reasonable cause is established: director disputes during the pandemic delayed account finalisation, while prompt upload after finalisation and absence of prejudice supported cancellation under section 271B.
Penalty for under-reported income is excluded where the taxpayer provides a bona fide explanation and fully discloses supporting material facts. Uploading audit records, paying relevant taxes before reassessment, and filing income accepted without additions supported cancellation under section 270A. Delayed tax-audit reporting does not attract penalty where reasonable cause is established: director disputes during the pandemic delayed account finalisation, while prompt upload after finalisation and absence of prejudice supported cancellation under section 271B.
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