Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
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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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