Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
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Penalty u/s. 271(l)(c) - Voluntary disclosure of income or not - revised return of income in which the assessee disclosed details of sale of immovable properties - It is a well-settled principle of law that if the assessee has made disclosure in the return of income, without the Department having brought the fact of omission on part of the assessee to the notice of the assessee, then it cannot be inferred that the revised return was filed pursuant to the omission having been detected by the Department. - AT
Penalty u/s. 271(l)(c) - Voluntary disclosure of income or not - revised return of income in which the assessee disclosed details of sale of immovable properties - It is a well-settled principle of law that if the assessee has made disclosure in the return of income, without the Department having brought the fact of omission on part of the assessee to the notice of the assessee, then it cannot be inferred that the revised return was filed pursuant to the omission having been detected by the Department. - AT
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