Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
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Penalty u/s 271(1)(c) - loss on sale of machinery - The Assessee contested the penalty, arguing that the omission of adding the loss on the sale of machinery to the total income was a bona fide mistake. The Tribunal observed a contradictory stand between the financial statement and the computation of income, indicating inadvertent errors. Considering the Assessee's participation in penalty proceedings and the submission of relevant documents, the Tribunal concluded that the penalty imposition was not justified.
Penalty u/s 271(1)(c) - loss on sale of machinery - The Assessee contested the penalty, arguing that the omission of adding the loss on the sale of machinery to the total income was a bona fide mistake. The Tribunal observed a contradictory stand between the financial statement and the computation of income, indicating inadvertent errors. Considering the Assessee's participation in penalty proceedings and the submission of relevant documents, the Tribunal concluded that the penalty imposition was not justified.
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