Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
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 ...
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Section 271(1)(c) treats concealment of income and furnishing inaccurate particulars as distinct penal defaults, requiring clear identification and proof of the specific charge. Mere non-disclosure does not establish inaccurate particulars unless the return contains incorrect or false details. An explanation offered during assessment, not found false and used to quantify the addition, may support bona fides and prevent application of Explanation 1. Although tax penalties do not require proof of mens rea, an addition alone does not make penalty automatic. On these facts, the absence of a specific default and failure to satisfy Explanation 1 led to deletion of the penalty.
Section 271(1)(c) treats concealment of income and furnishing inaccurate particulars as distinct penal defaults, requiring clear identification and proof of the specific charge. Mere non-disclosure does not establish inaccurate particulars unless the return contains incorrect or false details. An explanation offered during assessment, not found false and used to quantify the addition, may support bona fides and prevent application of Explanation 1. Although tax penalties do not require proof of mens rea, an addition alone does not make penalty automatic. On these facts, the absence of a specific default and failure to satisfy Explanation 1 led to deletion of the penalty.
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