Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Penalty u/s 271(1)(c) - non disclosure of capital gain on sale of land in the income tax return - Sale consideration by applying the provisions of section 50C (i.e deeming fiction) - It is an admitted fact that there cannot be any penalty on the profit calculated for the assessee based on deeming section/fiction. - the revenue is not expected to derive any benefit out of the ignorance of the assessee. - there was no deliberate act on part of the assessee to conceal/furnish inaccurate particulars of income - No penalty - AT
Penalty u/s 271(1)(c) - non disclosure of capital gain on sale of land in the income tax return - Sale consideration by applying the provisions of section 50C (i.e deeming fiction) - It is an admitted fact that there cannot be any penalty on the profit calculated for the assessee based on deeming section/fiction. - the revenue is not expected to derive any benefit out of the ignorance of the assessee. - there was no deliberate act on part of the assessee to conceal/furnish inaccurate particulars of income - No penalty - AT
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