Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Section 270A excludes from underreported income amounts for which a taxpayer offers a bona fide explanation and discloses material facts; where the return claimed a deduction based on an existing precedent, that explanation was treated as bona fide and no underreporting arose, so penalty under Section 270A could not be sustained. Separately, underreporting for penalty purposes arises only if assessed income exceeds income processed in the return; here the assessed income was not greater than the processed return, so prima facie penalty proceedings were unwarranted and the penalty order was stayed.
Section 270A excludes from underreported income amounts for which a taxpayer offers a bona fide explanation and discloses material facts; where the return claimed a deduction based on an existing precedent, that explanation was treated as bona fide and no underreporting arose, so penalty under Section 270A could not be sustained. Separately, underreporting for penalty purposes arises only if assessed income exceeds income processed in the return; here the assessed income was not greater than the processed return, so prima facie penalty proceedings were unwarranted and the penalty order was stayed.
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