Foreign portfolio investment liberalisation extends listed equity access to all individual persons resident outside India, subject to limit monitoring...
Unsubstantiated exempt agricultural income claim sustains concealment penalty after disclosure only on departmental detection and no bona fide evidenc...
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ITAT allowed the appeal in favour of the assessee and upheld the CIT(A)'s quashing of the penalty under s.271E. The Tribunal held the penalty order was time-barred under s.275(1)(c) since the limitation expired on 31.03.2023 but the penalty was imposed on 28.08.2023. Alternatively, the Tribunal found the transactions did not fall within the prohibitions of ss.269SS/269T and thus did not attract s.271E. The Tribunal also noted absence of requisite satisfaction recorded in the assessment order for initiating penalty proceedings, rendering any levy unsustainable. Consequently, the penalty was cancelled and the revenue's demand set aside.
ITAT allowed the appeal in favour of the assessee and upheld the CIT(A)'s quashing of the penalty under s.271E. The Tribunal held the penalty order was time-barred under s.275(1)(c) since the limitation expired on 31.03.2023 but the penalty was imposed on 28.08.2023. Alternatively, the Tribunal found the transactions did not fall within the prohibitions of ss.269SS/269T and thus did not attract s.271E. The Tribunal also noted absence of requisite satisfaction recorded in the assessment order for initiating penalty proceedings, rendering any levy unsustainable. Consequently, the penalty was cancelled and the revenue's demand set aside.
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