Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Imposition of personal penalty on the Partner of the Firm in terms of Section 78A of the Finance Act, 1994 - The case involved the imposition of a personal penalty on one of the partners of a partnership firm for alleged tax evasion. The tribunal ruled in favor of the appellant, stating that there was insufficient evidence to hold them personally liable and citing extenuating circumstances affecting tax payments. Additionally, the validity of a supplementary agreement absolving the appellant from liability was questioned, leading to a decision in favor of the appellant.
Imposition of personal penalty on the Partner of the Firm in terms of Section 78A of the Finance Act, 1994 - The case involved the imposition of a personal penalty on one of the partners of a partnership firm for alleged tax evasion. The tribunal ruled in favor of the appellant, stating that there was insufficient evidence to hold them personally liable and citing extenuating circumstances affecting tax payments. Additionally, the validity of a supplementary agreement absolving the appellant from liability was questioned, leading to a decision in favor of the appellant.
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