Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
Dominant issue: Whether penalties under sections 271D and 271E were leviable for cash loans. The Tribunal found on the substantive facts that the assessee's taxable income was below the limit and substantial receipts were agricultural income accepted by the AO, and lenders were agriculturists supported by affidavits and land-revenue records; thus the second proviso applied and no penalty could be sustained. Separately, the Tribunal held that bona fide cash dealings in the first year of a construction business, with genuine source and no tax-evasion motive, constitute reasonable cause under section 273B and warranted deletion of the penalties - ITAT
Dominant issue: Whether penalties under sections 271D and 271E were leviable for cash loans. The Tribunal found on the substantive facts that the assessee's taxable income was below the limit and substantial receipts were agricultural income accepted by the AO, and lenders were agriculturists supported by affidavits and land-revenue records; thus the second proviso applied and no penalty could be sustained. Separately, the Tribunal held that bona fide cash dealings in the first year of a construction business, with genuine source and no tax-evasion motive, constitute reasonable cause under section 273B and warranted deletion of the penalties - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4824 
Join Channel 
