Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Penalty u/s 271D / 271E - violation of provisions of Sec.269SS and 269T - basis of presumption u/s 132(4A) - Period of limitation - The Tribunal found that the penalty proceedings were not validly initiated due to the lack of satisfaction recorded in the assessment order regarding the violation of provisions of Sec.269SS. - It determined that the delay in moving the proposal for penalty proceedings after the conclusion of assessment proceedings was in violation of the CBDT Circular.
Penalty u/s 271D / 271E - violation of provisions of Sec.269SS and 269T - basis of presumption u/s 132(4A) - Period of limitation - The Tribunal found that the penalty proceedings were not validly initiated due to the lack of satisfaction recorded in the assessment order regarding the violation of provisions of Sec.269SS. - It determined that the delay in moving the proposal for penalty proceedings after the conclusion of assessment proceedings was in violation of the CBDT Circular.
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