SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Penalty u/s 271(1)(c) was levied by the Assessing Officer solely based on the order of the Income Tax Settlement Commission withdrawing immunity from penalty and prosecution, without adhering to the due process prescribed under the Act. The Assessing Officer failed to make reference to assessment proceedings, record satisfaction regarding concealment of income or furnishing inaccurate particulars, and issue notice u/s 274 before initiating penalty proceedings. The penalty proceedings u/s 271(1)(c) were arbitrary, not in accordance with law, and void ab initio. Regarding penalty u/s 271AAA, the Assessing Officer did not refer to the conditions prescribed, statement recorded u/s 132(4), or opportunity given to the assessee to explain the undisclosed income. Consequently, the initiation of penalty proceedings u/s 271AAA was illegal, and the penalties levied u/s 271AAA were quashed.
Penalty u/s 271(1)(c) was levied by the Assessing Officer solely based on the order of the Income Tax Settlement Commission withdrawing immunity from penalty and prosecution, without adhering to the due process prescribed under the Act. The Assessing Officer failed to make reference to assessment proceedings, record satisfaction regarding concealment of income or furnishing inaccurate particulars, and issue notice u/s 274 before initiating penalty proceedings. The penalty proceedings u/s 271(1)(c) were arbitrary, not in accordance with law, and void ab initio. Regarding penalty u/s 271AAA, the Assessing Officer did not refer to the conditions prescribed, statement recorded u/s 132(4), or opportunity given to the assessee to explain the undisclosed income. Consequently, the initiation of penalty proceedings u/s 271AAA was illegal, and the penalties levied u/s 271AAA were quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
