Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
Penalty u/s 271(1)(c) - Disallowance u/s 40(a)(ia) - AO has not applied his mind before initiating the penalty proceedings rather borrowed his satisfaction from the “tax audit report” and proceeded to initiate and levy the penalty which is not sustainable in the eyes of law. - Since the AO has not issued a valid notice by framing a specific charge to be initiated against the assessee rather invoked both the limbs of section 271(1)(c) of the Act for furnishing inaccurate particulars of income or for concealing the particulars of income no penalty can be imposed on the basis of the same. - AT
Penalty u/s 271(1)(c) - Disallowance u/s 40(a)(ia) - AO has not applied his mind before initiating the penalty proceedings rather borrowed his satisfaction from the “tax audit report” and proceeded to initiate and levy the penalty which is not sustainable in the eyes of law. - Since the AO has not issued a valid notice by framing a specific charge to be initiated against the assessee rather invoked both the limbs of section 271(1)(c) of the Act for furnishing inaccurate particulars of income or for concealing the particulars of income no penalty can be imposed on the basis of the same. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
