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...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
Penalty u/s 271(1)(c) was imposed for excess deduction claimed u/s 10B. The assessee furnished all relevant facts for computing total income, and provided detailed explanations regarding the claim u/s 10B, including the number of manufacturing divisions, bifurcation of expenditure, and availability of carried forward losses. The explanation was not found false, and the onus to prove falsity lies on the revenue. The claim was an allowable deduction, though the quantum was reworked by the Assessing Officer using different arithmetic. All details and justifications were provided in the return itself. The amount of tax sought to be evaded under explanation 1 to section 271(1)(c) was indeterminable for imposing penalty. The assessee's decision to not appeal the reduction of claim does not imply lack of bona fides. The CIT(A) rightly deleted the penalty, and no interference is warranted.
Penalty u/s 271(1)(c) was imposed for excess deduction claimed u/s 10B. The assessee furnished all relevant facts for computing total income, and provided detailed explanations regarding the claim u/s 10B, including the number of manufacturing divisions, bifurcation of expenditure, and availability of carried forward losses. The explanation was not found false, and the onus to prove falsity lies on the revenue. The claim was an allowable deduction, though the quantum was reworked by the Assessing Officer using different arithmetic. All details and justifications were provided in the return itself. The amount of tax sought to be evaded under explanation 1 to section 271(1)(c) was indeterminable for imposing penalty. The assessee's decision to not appeal the reduction of claim does not imply lack of bona fides. The CIT(A) rightly deleted the penalty, and no interference is warranted.
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