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Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Penalty proceedings u/s 271(1)(c) r.w.s. 274 - additional income declared in the return filed in response to notice u/s 153A as compared to original returned filed u/s 139(1) - There was no allegation of concealment or inaccurate particulars of income made by the Ld. AO or Ld. CIT(A) as the additional income was voluntarily disclosed in the return filed u/s 153A without any incriminating material found. - The Tribunal (ITAT) ultimately ruled in favor of the appellant, deleting both penalties levied u/s 271(1)(c).
Penalty proceedings u/s 271(1)(c) r.w.s. 274 - additional income declared in the return filed in response to notice u/s 153A as compared to original returned filed u/s 139(1) - There was no allegation of concealment or inaccurate particulars of income made by the Ld. AO or Ld. CIT(A) as the additional income was voluntarily disclosed in the return filed u/s 153A without any incriminating material found. - The Tribunal (ITAT) ultimately ruled in favor of the appellant, deleting both penalties levied u/s 271(1)(c).
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