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...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
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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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