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 allowed assessee's appeal against penalty under section 43 of Black Money Act for non-disclosure of foreign assets in income tax return. The assessee failed to declare Barclays Bank PLC Isle of Man investment in prescribed column, but her husband had properly disclosed the foreign bank accounts and interest income in his returns. The assessee subsequently filed updated return for AY 2022-23 disclosing foreign assets under FA Schedule. ITAT found the lapse inadvertent and non-malicious, noting bona fide compliance through husband's disclosures and assessee's cooperation during penalty proceedings including submission of bank statements and supporting documents. Following coordinate bench precedents, ITAT held that technical breaches arising from bona fide belief, where primary holder disclosed assets, do not warrant penal consequences. Revenue failed to prove assessee was beneficial owner or had willful intent to evade tax, making penalty unjustified and unsustainable.
ITAT allowed assessee's appeal against penalty under section 43 of Black Money Act for non-disclosure of foreign assets in income tax return. The assessee failed to declare Barclays Bank PLC Isle of Man investment in prescribed column, but her husband had properly disclosed the foreign bank accounts and interest income in his returns. The assessee subsequently filed updated return for AY 2022-23 disclosing foreign assets under FA Schedule. ITAT found the lapse inadvertent and non-malicious, noting bona fide compliance through husband's disclosures and assessee's cooperation during penalty proceedings including submission of bank statements and supporting documents. Following coordinate bench precedents, ITAT held that technical breaches arising from bona fide belief, where primary holder disclosed assets, do not warrant penal consequences. Revenue failed to prove assessee was beneficial owner or had willful intent to evade tax, making penalty unjustified and unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
