Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
The assessing officer (AO) is empowered u/s 275(1A) to revise the penalty order by giving a reasonable opportunity of hearing to the assessee within six months from the receipt of an appellate or revision order modifying the assessment. In the event the order passed by the Tribunal is modified by the High Court, the AO is required to give effect to the High Court's judgment by invoking Section 275(1A) and revise the penalty order accordingly. The CIT(A) correctly followed the Coordinate Bench decision and deleted the proportionate penalty levied by the AO to the extent of additions not confirmed by the Appellate Tribunal. The Revenue failed to demonstrate any stay order issued by the High Court against the Tribunal's order. Hence, the CIT(A)'s order confirming the penalty to the extent of additions confirmed by the Appellate Tribunal is upheld, and the Revenue's ground is dismissed.
The assessing officer (AO) is empowered u/s 275(1A) to revise the penalty order by giving a reasonable opportunity of hearing to the assessee within six months from the receipt of an appellate or revision order modifying the assessment. In the event the order passed by the Tribunal is modified by the High Court, the AO is required to give effect to the High Court's judgment by invoking Section 275(1A) and revise the penalty order accordingly. The CIT(A) correctly followed the Coordinate Bench decision and deleted the proportionate penalty levied by the AO to the extent of additions not confirmed by the Appellate Tribunal. The Revenue failed to demonstrate any stay order issued by the High Court against the Tribunal's order. Hence, the CIT(A)'s order confirming the penalty to the extent of additions confirmed by the Appellate Tribunal is upheld, and the Revenue's ground is dismissed.
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