Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
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.
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