Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
Revision u/s 264 - payment of tax on FTS under the DTAA at wrong rate (20% instead 10%) - it is not even denied by the Department that the Petitioner committed a mistake and should have paid tax at 10% - extra 10% paid by the Petitioner was of its own volition, it was indeed prejudicial to the Assessee - all the ingredients of Section 264 stand attracted hence permissible
Revision u/s 264 - payment of tax on FTS under the DTAA at wrong rate (20% instead 10%) - it is not even denied by the Department that the Petitioner committed a mistake and should have paid tax at 10% - extra 10% paid by the Petitioner was of its own volition, it was indeed prejudicial to the Assessee - all the ingredients of Section 264 stand attracted hence permissible
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
