Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
ITAT held that recording of satisfaction by the AO is a condition precedent to initiate penalty proceedings under s.271D for alleged contravention of s.269SS, and where the AO's satisfaction was embodied in the assessment order dated 30-12-2022 after statutory approval by the Addl. CIT, that date constitutes the date on which "action for imposition of penalty is considered as initiated" for purposes of s.275(1)(c). Applying the prescribed limitation, the penalty order had to be passed by 30-06-2023; the impugned penalty dated 31-08-2023 was therefore time-barred and held non est. The penalty order is quashed.
ITAT held that recording of satisfaction by the AO is a condition precedent to initiate penalty proceedings under s.271D for alleged contravention of s.269SS, and where the AO's satisfaction was embodied in the assessment order dated 30-12-2022 after statutory approval by the Addl. CIT, that date constitutes the date on which "action for imposition of penalty is considered as initiated" for purposes of s.275(1)(c). Applying the prescribed limitation, the penalty order had to be passed by 30-06-2023; the impugned penalty dated 31-08-2023 was therefore time-barred and held non est. The penalty order is quashed.
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