SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
ITAT held that the penalty proceedings u/s 271(1)(c) are vitiated due to non-striking of irrelevant limbs in the show cause notice, which violates principles of natural justice. The tribunal found the omnibus notice demonstrated non-application of mind by the Assessing Officer. Despite voluntary disclosure of additional income post-survey, the assessee failed to establish unintentional concealment. Relying on precedent, the tribunal concluded that mere surrender of income does not automatically absolve penalty proceedings. Consequently, the appeal was dismissed, upholding the penalty levied by the lower authorities.
ITAT held that the penalty proceedings u/s 271(1)(c) are vitiated due to non-striking of irrelevant limbs in the show cause notice, which violates principles of natural justice. The tribunal found the omnibus notice demonstrated non-application of mind by the Assessing Officer. Despite voluntary disclosure of additional income post-survey, the assessee failed to establish unintentional concealment. Relying on precedent, the tribunal concluded that mere surrender of income does not automatically absolve penalty proceedings. Consequently, the appeal was dismissed, upholding the penalty levied by the lower authorities.
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