Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Penalty proceedings u/s 271(1)(c) - Failure of the assessee to explain the source of cash deposit in the bank account - burden of proof - The ITAT acknowledged the difference in the burden of proof between penalty proceedings and assessment proceedings. Mere disallowance or addition in quantum proceedings does not automatically warrant penalty imposition under Section 271(1)(c) of the Act. - Considering the mitigating circumstances, including the deceased status of the appellant and the difficulty in independently proving circumstantial facts, the tribunal concluded that the penalty imposition was not justified and directed its reversal and deletion.
Penalty proceedings u/s 271(1)(c) - Failure of the assessee to explain the source of cash deposit in the bank account - burden of proof - The ITAT acknowledged the difference in the burden of proof between penalty proceedings and assessment proceedings. Mere disallowance or addition in quantum proceedings does not automatically warrant penalty imposition under Section 271(1)(c) of the Act. - Considering the mitigating circumstances, including the deceased status of the appellant and the difficulty in independently proving circumstantial facts, the tribunal concluded that the penalty imposition was not justified and directed its reversal and deletion.
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