Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
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Appellant's conduct showed mentality of evading taxes, not cooperating from filing return till assessment. Though penalty order was in 2002, appellant did not file compounding application even after that date or before conviction in 2019, dragging issue for 20 years. Default termed wilful. Circular No.25/2019 did not intend to extend compounding benefit to all who applied by 31.12.2019. Rejection of compounding application upheld as appellant's application was belated and no scope for compounding after conviction under direct tax laws. Paying tax, penalty and interest does not entitle compounding. Authorities rightly rejected compounding application.
Appellant's conduct showed mentality of evading taxes, not cooperating from filing return till assessment. Though penalty order was in 2002, appellant did not file compounding application even after that date or before conviction in 2019, dragging issue for 20 years. Default termed wilful. Circular No.25/2019 did not intend to extend compounding benefit to all who applied by 31.12.2019. Rejection of compounding application upheld as appellant's application was belated and no scope for compounding after conviction under direct tax laws. Paying tax, penalty and interest does not entitle compounding. Authorities rightly rejected compounding application.
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