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...
Concurrent factual findings on cash credits recorded in an impounded diary did not give rise to a substantial question of law in the income-tax appeals. The credits recorded in a partner's name were treated as unaccounted funds introduced by the partner into the partnership firm after considering the stated unaccounted sources. A plea to assess the entire diary amount in the partner's hands required reconsideration of those factual findings rather than resolution of a legal issue. The challenges therefore failed for want of a substantial question of law.
Concurrent factual findings on cash credits recorded in an impounded diary did not give rise to a substantial question of law in the income-tax appeals. The credits recorded in a partner's name were treated as unaccounted funds introduced by the partner into the partnership firm after considering the stated unaccounted sources. A plea to assess the entire diary amount in the partner's hands required reconsideration of those factual findings rather than resolution of a legal issue. The challenges therefore failed for want of a substantial question of law.
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