Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Penalty u/s 271(c) was imposed on additions of 25% of non-verifiable purchases debited to the trading account. The addition was made on estimation of total turnover after rejecting the books of accounts. Notices u/s 133(6) were issued to various purchase parties, but all were returned by the postal authority, and the assessee did not produce the parties to confirm the same. The lower authorities observed that the revenue did not establish that the assessee had concealed or submitted inaccurate particulars of income to attract Section 271(1)(c). The addition was admittedly made on an estimate basis. The ratio of the judgment in Parasamal Babulal Jain and various ITAT pronouncements covered the assessee's case. Since the addition was made on an estimate basis, the penalty was rightly deleted by the CIT(A). The ITAT found no illegality in the CIT(A)'s order and confirmed it, deciding against the revenue.
Penalty u/s 271(c) was imposed on additions of 25% of non-verifiable purchases debited to the trading account. The addition was made on estimation of total turnover after rejecting the books of accounts. Notices u/s 133(6) were issued to various purchase parties, but all were returned by the postal authority, and the assessee did not produce the parties to confirm the same. The lower authorities observed that the revenue did not establish that the assessee had concealed or submitted inaccurate particulars of income to attract Section 271(1)(c). The addition was admittedly made on an estimate basis. The ratio of the judgment in Parasamal Babulal Jain and various ITAT pronouncements covered the assessee's case. Since the addition was made on an estimate basis, the penalty was rightly deleted by the CIT(A). The ITAT found no illegality in the CIT(A)'s order and confirmed it, deciding against the revenue.
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