Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
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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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