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...
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The ITAT held that the penalty under section 271(1)(c) was unsustainable as the Assessing Officer failed to record satisfaction specifically whether the assessee concealed particulars of income or furnished inaccurate particulars, a mandatory precondition for initiating penalty proceedings. The AO issued the notice under section 274 read with section 271(1)(c) in a standard proforma without deleting irrelevant portions, indicating non-application of mind. Consequently, the penalty notice was invalid for lack of clarity and specificity, denying the assessee adequate opportunity to respond. The tribunal quashed the penalty order, allowing the appeal, reaffirming that proper satisfaction and clear specification of charge are essential prerequisites before imposing penalty under section 271(1)(c).
The ITAT held that the penalty under section 271(1)(c) was unsustainable as the Assessing Officer failed to record satisfaction specifically whether the assessee concealed particulars of income or furnished inaccurate particulars, a mandatory precondition for initiating penalty proceedings. The AO issued the notice under section 274 read with section 271(1)(c) in a standard proforma without deleting irrelevant portions, indicating non-application of mind. Consequently, the penalty notice was invalid for lack of clarity and specificity, denying the assessee adequate opportunity to respond. The tribunal quashed the penalty order, allowing the appeal, reaffirming that proper satisfaction and clear specification of charge are essential prerequisites before imposing penalty under section 271(1)(c).
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