Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
HC held that penalty proceedings initiated under two sections simultaneously are valid, but satisfaction must be recorded during assessment proceedings. The AO cannot record reasons for penalty after proceedings conclude. The tribunal's order quashing the revisional authority's directive was upheld, effectively ruling against the revenue. The core legal principle emphasizes that procedural satisfaction for imposing penalties must be contemporaneous with assessment proceedings, not retrospectively constructed. The decision reinforces strict procedural compliance in tax penalty impositions, ensuring that administrative discretion is exercised within prescribed temporal boundaries.
HC held that penalty proceedings initiated under two sections simultaneously are valid, but satisfaction must be recorded during assessment proceedings. The AO cannot record reasons for penalty after proceedings conclude. The tribunal's order quashing the revisional authority's directive was upheld, effectively ruling against the revenue. The core legal principle emphasizes that procedural satisfaction for imposing penalties must be contemporaneous with assessment proceedings, not retrospectively constructed. The decision reinforces strict procedural compliance in tax penalty impositions, ensuring that administrative discretion is exercised within prescribed temporal boundaries.
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