Human-probability test defeats political donation deduction where banking records mask accommodation-entry fund layering and evidence shows non-genuin...
Commercial property status protects capital-gains exemption when residential-house ownership limits are tested, while agricultural-land character gove...
Investigation deposits refunded after failed customs demands fall outside the statutory appellate pre-deposit interest regime and may attract compensa...
Resolution plan finality extinguishes unquantified operational-creditor claims and pending proceedings unless the approved plan expressly preserves th...
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 
