Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengea...
Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Penalty u/s 271(1)(c) - There cannot be a penalty merely on the basis that the assessee has disclosed income after receiving the notice from the ADIT and the income was accepted during survey proceedings - No incriminating documents discovered during the course of survey at the premises of the assessee. Similarly, the additional income offered by the assessee in return filed in response to notice under section 148 of the Act admitted as it is by the AO. - No penalty - AT
Penalty u/s 271(1)(c) - There cannot be a penalty merely on the basis that the assessee has disclosed income after receiving the notice from the ADIT and the income was accepted during survey proceedings - No incriminating documents discovered during the course of survey at the premises of the assessee. Similarly, the additional income offered by the assessee in return filed in response to notice under section 148 of the Act admitted as it is by the AO. - No penalty - AT
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