Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
ITAT deleted the impugned penalty under s.270A, holding that the assessee's reclassification of receipts from business income to long-term capital gains-premised on prevailing judicial decisions and a CBDT circular-did not constitute under-reporting or misreporting of income. The Tribunal found the charge insufficiently specified and concluded the factual and legal position favored the assessee, thereby allowing the effective grounds of appeal and quashing the penalty. The decision follows applicable precedent and resolves that no penalty liability arises where taxability was genuinely contested and determined in favour of capital gains treatment.
ITAT deleted the impugned penalty under s.270A, holding that the assessee's reclassification of receipts from business income to long-term capital gains-premised on prevailing judicial decisions and a CBDT circular-did not constitute under-reporting or misreporting of income. The Tribunal found the charge insufficiently specified and concluded the factual and legal position favored the assessee, thereby allowing the effective grounds of appeal and quashing the penalty. The decision follows applicable precedent and resolves that no penalty liability arises where taxability was genuinely contested and determined in favour of capital gains treatment.
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