Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Penalty u/s 271(1)(c) was imposed on the assessee for not filing the return of income (ROI), despite having a bona fide belief that the income was non-taxable and tax deducted at source (TDS) was deducted on the income. The assessee, a non-profit welfare fund, filed the return and paid the tax in full after receiving a notice u/s 148, before receiving the recorded reasons. The Assessing Officer accepted the return and tax paid, with no findings of concealment of income. Relying on relevant judicial precedents, the Tribunal held that the levy of penalty was unjustified and quashed the penalty u/s 271(1)(c), allowing the assessee's appeal.
Penalty u/s 271(1)(c) was imposed on the assessee for not filing the return of income (ROI), despite having a bona fide belief that the income was non-taxable and tax deducted at source (TDS) was deducted on the income. The assessee, a non-profit welfare fund, filed the return and paid the tax in full after receiving a notice u/s 148, before receiving the recorded reasons. The Assessing Officer accepted the return and tax paid, with no findings of concealment of income. Relying on relevant judicial precedents, the Tribunal held that the levy of penalty was unjustified and quashed the penalty u/s 271(1)(c), allowing the assessee's appeal.
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