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...
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The ITAT upheld the AO's imposition of penalty under section 271(1)(c) for bogus purchases, affirming that the onus lies on the assessee to substantiate claims made in the return of income. The CIT(A)'s acceptance of non-compliance as justification for non-submission of details was rejected to prevent setting a detrimental precedent. Given the assessee's failure to furnish necessary particulars during assessment, penalty, and appellate proceedings, the AO's determination of bogus purchases was sustained. Additionally, despite disallowance under section 40(a)(ia) in computation, the assessee did not reflect this in the ITR, justifying penalty imposition. The ITAT relied on precedent emphasizing deterrence against inaccurate returns and reversed the CIT(A)'s deletion of penalty. Consequently, the revenue's appeal was allowed, confirming the penalty levy by the AO.
The ITAT upheld the AO's imposition of penalty under section 271(1)(c) for bogus purchases, affirming that the onus lies on the assessee to substantiate claims made in the return of income. The CIT(A)'s acceptance of non-compliance as justification for non-submission of details was rejected to prevent setting a detrimental precedent. Given the assessee's failure to furnish necessary particulars during assessment, penalty, and appellate proceedings, the AO's determination of bogus purchases was sustained. Additionally, despite disallowance under section 40(a)(ia) in computation, the assessee did not reflect this in the ITR, justifying penalty imposition. The ITAT relied on precedent emphasizing deterrence against inaccurate returns and reversed the CIT(A)'s deletion of penalty. Consequently, the revenue's appeal was allowed, confirming the penalty levy by the AO.
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