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Interim judicial restraint preventing treatment of foreign-leg...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursements.
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Interim judicial restraint preventing treatment of foreign-leg Leave Fare Concession reimbursements as income for tax-deduction purposes meant the deductor did not breach an enforceable deduction obligation; tax-default demands and consequential interest were therefore deleted. Subsequent substantive taxability could not retrospectively turn compliance with the subsisting direction into a default. Compliance with that direction also constituted statutory reasonable cause, supporting deletion of non-deduction penalties. Institutional delays in penalty appeals were condoned where multi-level approvals, lost portal access after personnel changes, and access resetting showed sufficient cause without deliberate delay, mala fides, benefit to the deductor, or prejudice to revenue.
Interim judicial restraint preventing treatment of foreign-leg Leave Fare Concession reimbursements as income for tax-deduction purposes meant the deductor did not breach an enforceable deduction obligation; tax-default demands and consequential interest were therefore deleted. Subsequent substantive taxability could not retrospectively turn compliance with the subsisting direction into a default. Compliance with that direction also constituted statutory reasonable cause, supporting deletion of non-deduction penalties. Institutional delays in penalty appeals were condoned where multi-level approvals, lost portal access after personnel changes, and access resetting showed sufficient cause without deliberate delay, mala fides, benefit to the deductor, or prejudice to revenue.
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