Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
This case deals with the levy of penalties u/ss 271AAA and 271(1)(c) of the Income Tax Act in relation to various additions made to the assessee's income based on seized documents during a search operation. The key points are: Penalty u/s 271AAA upheld for undisclosed consideration from land sale based on seized documents mentioning assessee's name and transaction details. Assessee failed to rebut the evidence. Penalty upheld for undisclosed capital gains from land sale confirmed by appellate authorities based on seized material. Penalty u/s 271AAA deleted for additions made on a protective basis, following judicial precedents. Penalties u/ss 271AAA and 271(1)(c) are mutually exclusive for the same assessment year. Penalty u/s 271(1)(c) upheld for unexplained bank deposits as assessee failed to provide explanations, and additions were confirmed by appellate authorities in quantum proceedings. Penalty u/s 271(1)(c) deleted for additions based solely on seized documents without corroborative evidence regarding the purchase of property by the assessee and their father. Mere entries in seized material were insufficient. Penalty u/s 271(1)(c) upheld for unexplained bank deposits in the assessee's brother's account, as the assessee could not provide a plaus.
This case deals with the levy of penalties u/ss 271AAA and 271(1)(c) of the Income Tax Act in relation to various additions made to the assessee's income based on seized documents during a search operation. The key points are: Penalty u/s 271AAA upheld for undisclosed consideration from land sale based on seized documents mentioning assessee's name and transaction details. Assessee failed to rebut the evidence. Penalty upheld for undisclosed capital gains from land sale confirmed by appellate authorities based on seized material. Penalty u/s 271AAA deleted for additions made on a protective basis, following judicial precedents. Penalties u/ss 271AAA and 271(1)(c) are mutually exclusive for the same assessment year. Penalty u/s 271(1)(c) upheld for unexplained bank deposits as assessee failed to provide explanations, and additions were confirmed by appellate authorities in quantum proceedings. Penalty u/s 271(1)(c) deleted for additions based solely on seized documents without corroborative evidence regarding the purchase of property by the assessee and their father. Mere entries in seized material were insufficient. Penalty u/s 271(1)(c) upheld for unexplained bank deposits in the assessee's brother's account, as the assessee could not provide a plaus.
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