Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
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Tribunal addressed levy of penalty under section 271AAB(1A) focusing on whether the addition constituted undisclosed income under Explanation clause (c). The Tribunal reasoned that clause (c) requires money, valuables, or entries or transactions found during a search indicating incriminating material; absent such material the statutory condition for penalty is unmet, so the penalty cannot be sustained. The AO had taxed the amount under income reconstruction principles but, since no incriminating material was found during search proceedings, the penalty under section 271AAB(1A) was deleted and relief granted to the assessee.
Tribunal addressed levy of penalty under section 271AAB(1A) focusing on whether the addition constituted undisclosed income under Explanation clause (c). The Tribunal reasoned that clause (c) requires money, valuables, or entries or transactions found during a search indicating incriminating material; absent such material the statutory condition for penalty is unmet, so the penalty cannot be sustained. The AO had taxed the amount under income reconstruction principles but, since no incriminating material was found during search proceedings, the penalty under section 271AAB(1A) was deleted and relief granted to the assessee.
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