Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT ruled against penalty under s.270A for under-reporting income. Taxpayer met substantive conditions for immunity under s.270AA(1) by paying assessed tax and interest within prescribed time after declaring Rs.30 lakhs under PMGKY scheme. While Form 68 wasn't filed with AO, ITAT held this procedural omission shouldn't override substantive compliance. Citing principle that technical procedures shouldn't impede substantial justice, tribunal found non-filing of Form 68 was merely technical breach. Since taxpayer satisfied core requirements of s.270AA(1)(a)&(b), immunity from penalty was granted despite procedural lapse. Appeal decided in taxpayer's favor, setting aside penalty under s.270A.
ITAT ruled against penalty under s.270A for under-reporting income. Taxpayer met substantive conditions for immunity under s.270AA(1) by paying assessed tax and interest within prescribed time after declaring Rs.30 lakhs under PMGKY scheme. While Form 68 wasn't filed with AO, ITAT held this procedural omission shouldn't override substantive compliance. Citing principle that technical procedures shouldn't impede substantial justice, tribunal found non-filing of Form 68 was merely technical breach. Since taxpayer satisfied core requirements of s.270AA(1)(a)&(b), immunity from penalty was granted despite procedural lapse. Appeal decided in taxpayer's favor, setting aside penalty under s.270A.
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