Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
ITAT allowed the appeal and deleted the penalty levied under s. 270A(9) against the assessee, holding that the impugned disallowance related solely to an erroneous calculation of deduction under s. 54F rather than misrepresentation or suppression of facts. The Tribunal found that the assessee had disclosed the capital gains and the investment facts, and neither the AO nor the CIT(A) identified any specific instance within sub-s. (9) of s. 270A that was satisfied. Consequently, the penalty for mis-reporting was unsustainable as a matter of law and was set aside, with the appeal of the assessee being allowed.
ITAT allowed the appeal and deleted the penalty levied under s. 270A(9) against the assessee, holding that the impugned disallowance related solely to an erroneous calculation of deduction under s. 54F rather than misrepresentation or suppression of facts. The Tribunal found that the assessee had disclosed the capital gains and the investment facts, and neither the AO nor the CIT(A) identified any specific instance within sub-s. (9) of s. 270A that was satisfied. Consequently, the penalty for mis-reporting was unsustainable as a matter of law and was set aside, with the appeal of the assessee being allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
