Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Issue: Whether a Revisional order under section 263 can direct initiation of penalty under section 271E absent the Assessing Officer's satisfaction in the assessment order. Reasoning: Relying on the Supreme Court principle that initiation/levy of penalty under s.271E requires satisfaction recorded in the assessment, the Revisional Authority erred in treating penalty initiation as independent of AO's satisfaction and in distinguishing earlier High Court precedent. Outcome: The section 263 order directing initiation of penalty under s.271E was unsustainable and is set aside; appeal allowed. - ITAT
Issue: Whether a Revisional order under section 263 can direct initiation of penalty under section 271E absent the Assessing Officer's satisfaction in the assessment order. Reasoning: Relying on the Supreme Court principle that initiation/levy of penalty under s.271E requires satisfaction recorded in the assessment, the Revisional Authority erred in treating penalty initiation as independent of AO's satisfaction and in distinguishing earlier High Court precedent. Outcome: The section 263 order directing initiation of penalty under s.271E was unsustainable and is set aside; appeal allowed. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
