Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
ITAT reversed penalties imposed under s271(1)(c) and s271AAB against assessee regarding disputed cash expenses and labor payments. AO's additions were initially made at 50%, reduced to 35% by CIT(A), and further reduced to 20% by Coordinate Bench. Despite CIT(A)'s observation of assessee's alleged malafide intent and mens rea, ITAT held that penalties cannot be imposed on additions made purely on estimate basis, following established precedent. The Tribunal noted AO's irresponsible approach and lack of judicial discipline in penalty proceedings, particularly given the Coordinate Bench's prior findings on quantum additions. Appeal allowed in assessee's favor with complete deletion of penalties.
ITAT reversed penalties imposed under s271(1)(c) and s271AAB against assessee regarding disputed cash expenses and labor payments. AO's additions were initially made at 50%, reduced to 35% by CIT(A), and further reduced to 20% by Coordinate Bench. Despite CIT(A)'s observation of assessee's alleged malafide intent and mens rea, ITAT held that penalties cannot be imposed on additions made purely on estimate basis, following established precedent. The Tribunal noted AO's irresponsible approach and lack of judicial discipline in penalty proceedings, particularly given the Coordinate Bench's prior findings on quantum additions. Appeal allowed in assessee's favor with complete deletion of penalties.
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