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...
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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
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