Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Penalty u/s.271(1)(c) - claimed higher deduction u/s.36(1)(viia) based on opinion of the Central Statutory Auditors - latter on based on different view canvassed against the other banks, reduced the claim of deduction to the actual amount of provision created in the books of account by revised return - it is a clear cut case of bona fide opinion - no penalty
Penalty u/s.271(1)(c) - claimed higher deduction u/s.36(1)(viia) based on opinion of the Central Statutory Auditors - latter on based on different view canvassed against the other banks, reduced the claim of deduction to the actual amount of provision created in the books of account by revised return - it is a clear cut case of bona fide opinion - no penalty
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