International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
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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