Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
HC quashed penalty u/s 271(1)(c) for non-filing of ITR within prescribed period, ruling no concealment of income occurred. Assessee had uploaded financial statements and tax audit report, paid all taxes, but failed to file ITR due to inadvertent human error, subsequently filing upon s.148 notice. Court held Explanation 3 targets dishonest persons concealing income to evade taxes, not bonafide mistakes where no tax liability exists. Since assessee was entitled to refund with no concealment of particulars, AO erred in applying s.271(1)(c) and calculating penalty amount. Both AO and Revisional Authority failed to appreciate factual circumstances. Assessee's appeal allowed, penalty set aside.
HC quashed penalty u/s 271(1)(c) for non-filing of ITR within prescribed period, ruling no concealment of income occurred. Assessee had uploaded financial statements and tax audit report, paid all taxes, but failed to file ITR due to inadvertent human error, subsequently filing upon s.148 notice. Court held Explanation 3 targets dishonest persons concealing income to evade taxes, not bonafide mistakes where no tax liability exists. Since assessee was entitled to refund with no concealment of particulars, AO erred in applying s.271(1)(c) and calculating penalty amount. Both AO and Revisional Authority failed to appreciate factual circumstances. Assessee's appeal allowed, penalty set aside.
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