Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under sect...
Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Proceeds of crime: provisional attachment confirmed; equivalent value attachment and acquisition date fair market value upheld, Covid exclusion preser...
Where an assessee obtained a certificate under the Direct Tax Dispute Resolution Scheme, 2016, the settlement order under s. 204(1) was held conclusive under s. 204(3), barring reopening of matters covered by it under the Act. Consequently, immunity from penalty proceedings operated generally, making it immaterial whether penalty would otherwise fall under s. 271AAB or s. 271AB. A revision initiated on audit objection to direct a de novo penalty order on the premise of applying a different penalty provision was unsustainable, and no substantial question of law arose. - HC
Where an assessee obtained a certificate under the Direct Tax Dispute Resolution Scheme, 2016, the settlement order under s. 204(1) was held conclusive under s. 204(3), barring reopening of matters covered by it under the Act. Consequently, immunity from penalty proceedings operated generally, making it immaterial whether penalty would otherwise fall under s. 271AAB or s. 271AB. A revision initiated on audit objection to direct a de novo penalty order on the premise of applying a different penalty provision was unsustainable, and no substantial question of law arose. - HC
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