Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
Levy of penalties u/s 271D and 271E for the violation of sections 269SS and 269T, respectively - The Tribunal, after reviewing precedents from the Supreme Court and various High Courts, emphasized that recording satisfaction in the assessment order regarding the initiation of penalty proceedings is mandatory. It was found that the AO had not recorded such satisfaction, rendering the penalty proceedings under sections 271D and 271E invalid. - Regarding period of limitation, the Tribunal noted that the reference for initiating penalty proceedings made by the AO to the Additional Commissioner was beyond the statutory limitation period. Therefore, the penalties imposed were considered time-barred and legally unsustainable.
Levy of penalties u/s 271D and 271E for the violation of sections 269SS and 269T, respectively - The Tribunal, after reviewing precedents from the Supreme Court and various High Courts, emphasized that recording satisfaction in the assessment order regarding the initiation of penalty proceedings is mandatory. It was found that the AO had not recorded such satisfaction, rendering the penalty proceedings under sections 271D and 271E invalid. - Regarding period of limitation, the Tribunal noted that the reference for initiating penalty proceedings made by the AO to the Additional Commissioner was beyond the statutory limitation period. Therefore, the penalties imposed were considered time-barred and legally unsustainable.
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TaxTMI 
TaxTMI 
of 4881 
