Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Levy of penalty u/s. 271(1)(c) - disallowance made u/s. 35(2AB) - The Tribunal referred to the decision of the Hon’ble Supreme Court in the case of CIT vs. Reliance Petroproducts Pvt. Ltd., where it was held that the term 'particulars' under section 271(1)(c) includes the details of the claim made. In the absence of any incorrect or inaccurate information provided in the return, penalty cannot be imposed for furnishing inaccurate particulars. - Since the DSIR approval was not available to the assessee at the time of filing the return, any subsequent restriction on the deduction claimed cannot be considered as furnishing inaccurate particulars of income.
Levy of penalty u/s. 271(1)(c) - disallowance made u/s. 35(2AB) - The Tribunal referred to the decision of the Hon’ble Supreme Court in the case of CIT vs. Reliance Petroproducts Pvt. Ltd., where it was held that the term 'particulars' under section 271(1)(c) includes the details of the claim made. In the absence of any incorrect or inaccurate information provided in the return, penalty cannot be imposed for furnishing inaccurate particulars. - Since the DSIR approval was not available to the assessee at the time of filing the return, any subsequent restriction on the deduction claimed cannot be considered as furnishing inaccurate particulars of income.
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