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 ...
Penalty u/s. 271(1)(c) - Referring to a precedent set by the Hon’ble Supreme Court in CIT vs. Suresh Chandra Mittal, the Tribunal emphasized that when an assessee voluntarily discloses additional income to resolve tax disputes, such disclosure should be considered bona fide. - The Tribunal observed that the vouchers for the purchases were self-made and subsequently treated as bogus by the AO. It concluded that this situation mirrored the circumstances in the Suresh Chandra Mittal case, where penalties were canceled due to the assessee's bona fide explanation. Consequently, the Tribunal deleted the penalties imposed by the AO.
Penalty u/s. 271(1)(c) - Referring to a precedent set by the Hon’ble Supreme Court in CIT vs. Suresh Chandra Mittal, the Tribunal emphasized that when an assessee voluntarily discloses additional income to resolve tax disputes, such disclosure should be considered bona fide. - The Tribunal observed that the vouchers for the purchases were self-made and subsequently treated as bogus by the AO. It concluded that this situation mirrored the circumstances in the Suresh Chandra Mittal case, where penalties were canceled due to the assessee's bona fide explanation. Consequently, the Tribunal deleted the penalties imposed by the AO.
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