Blocked input tax credit for resort construction remains unavailable; interest follows actual utilisation, while delayed payment attracts statutory pe...
Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
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The ITAT upheld the deletion of the penalty under section 271(1)(c) where the assessee voluntarily disclosed undisclosed income in the return filed under section 153A, which was accepted by the AO. The Tribunal found no incriminating material during the search regarding the disclosed income, which related to outstanding liabilities reflected in the books. Since the surrendered income was admitted and taxed without concealment or furnishing inaccurate particulars, the imposition of penalty was unwarranted. The CIT(A)'s acceptance of the income return reflecting a substantial loss further supported the absence of tax evasion. Consequently, the penalty was quashed, and the assessee's appeal was allowed.
The ITAT upheld the deletion of the penalty under section 271(1)(c) where the assessee voluntarily disclosed undisclosed income in the return filed under section 153A, which was accepted by the AO. The Tribunal found no incriminating material during the search regarding the disclosed income, which related to outstanding liabilities reflected in the books. Since the surrendered income was admitted and taxed without concealment or furnishing inaccurate particulars, the imposition of penalty was unwarranted. The CIT(A)'s acceptance of the income return reflecting a substantial loss further supported the absence of tax evasion. Consequently, the penalty was quashed, and the assessee's appeal was allowed.
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