Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Penalty u/s 271AAB/271(1)(c) - cash was seized u/s 132A - the discrepancies were found during the survey - Obviously, no penalty can be imposed unless the conditions stipulated in the said provisions are duly and unambiguously satisfied. Since the assessee was exposed during survey, may be, it would have not disclosed the income but for the said survey. However, there cannot be any penalty only on surmises, conjectures and possibilities. Section 271(1)(c) of the Act has to be construed strictly. - AT
Penalty u/s 271AAB/271(1)(c) - cash was seized u/s 132A - the discrepancies were found during the survey - Obviously, no penalty can be imposed unless the conditions stipulated in the said provisions are duly and unambiguously satisfied. Since the assessee was exposed during survey, may be, it would have not disclosed the income but for the said survey. However, there cannot be any penalty only on surmises, conjectures and possibilities. Section 271(1)(c) of the Act has to be construed strictly. - AT
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