Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Penalty u/s 271(1)(c) - assessee claimed depreciation u/s 32 on road constructed on Build-Operate-Transfer basis which was denied - the Revenue had itself accepted that there was a doubt and that is why the clarification of 2014 was issued. Had it been so cut and dried there was no occasion for the Board to have issued the clarification and infact, this is precisely what weighed with CIT(A) and ITAT - no penalty
Penalty u/s 271(1)(c) - assessee claimed depreciation u/s 32 on road constructed on Build-Operate-Transfer basis which was denied - the Revenue had itself accepted that there was a doubt and that is why the clarification of 2014 was issued. Had it been so cut and dried there was no occasion for the Board to have issued the clarification and infact, this is precisely what weighed with CIT(A) and ITAT - no penalty
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