Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
HC upheld ITAT's ruling against penalty under s.271C, accepting assessee's reasonable cause defense for TDS non-deduction. Assessee's reliance on legal opinions from Singhania & Co. and Lovelock & Lewis demonstrated bona fide belief. Court considered significant that assessee had sought advance ruling, which remained unprocessed due to Authority Chairman's personal reasons. HC found no mala fide intent, noting assessee derived no benefit from non-deduction. Multiple factors constituted reasonable cause under law, validating non-imposition of penalty. Assessee's explanation sufficiently established absence of willful default, justifying relief from punitive measures.
HC upheld ITAT's ruling against penalty under s.271C, accepting assessee's reasonable cause defense for TDS non-deduction. Assessee's reliance on legal opinions from Singhania & Co. and Lovelock & Lewis demonstrated bona fide belief. Court considered significant that assessee had sought advance ruling, which remained unprocessed due to Authority Chairman's personal reasons. HC found no mala fide intent, noting assessee derived no benefit from non-deduction. Multiple factors constituted reasonable cause under law, validating non-imposition of penalty. Assessee's explanation sufficiently established absence of willful default, justifying relief from punitive measures.
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TaxTMI 
TaxTMI 
of 4915 
