Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Penalty u/s 27(1)(c) - invocation of provisions of Section 263 - while the Pr.CIT could well initiate penalty u/s 271(1) if he proposed to effect modifications to the assessment itself, he cannot, in law substitute his satisfaction for that of the Assessing Officers’ for levying penalty in regard to the modifications to income effected in original assessment.
Penalty u/s 27(1)(c) - invocation of provisions of Section 263 - while the Pr.CIT could well initiate penalty u/s 271(1) if he proposed to effect modifications to the assessment itself, he cannot, in law substitute his satisfaction for that of the Assessing Officers’ for levying penalty in regard to the modifications to income effected in original assessment.
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