Maintainability of a Section 7 insolvency petition against a financial service provider denied; appeal dismissed for non maintainability and complex d...
Provisional attachment under Prevention of Money Laundering Act requires exhaustion of statutory remedies; impugned order set aside, appeal to tribuna...
Restoration of property under Prevention of Money Laundering Act after attachment dispute rendered academic; possession directed to successful resolut...
Goods Transport Agency services via e commerce portals: consignment note creates custody and liability and enables exemption for unregistered recipien...
Penalty under section 271(1)(c) was contested where taxability of interest and commitment fees turned on interpretation of the India Germany DTAA and whether a representative office constituted a Permanent Establishment; AO taxed receipts at 40% but Tribunal treated them under Article 11 at 10%. The CIT(A) and Tribunal found the addition arose from the assessee's voluntary disclosures and a bona fide difference of opinion, invoking Reliance Petroproducts that an unsustainable claim alone does not constitute furnishing inaccurate particulars. Consequently no penalty was warranted and the appellant's appeal was allowed.
Penalty under section 271(1)(c) was contested where taxability of interest and commitment fees turned on interpretation of the India Germany DTAA and whether a representative office constituted a Permanent Establishment; AO taxed receipts at 40% but Tribunal treated them under Article 11 at 10%. The CIT(A) and Tribunal found the addition arose from the assessee's voluntary disclosures and a bona fide difference of opinion, invoking Reliance Petroproducts that an unsustainable claim alone does not constitute furnishing inaccurate particulars. Consequently no penalty was warranted and the appellant's appeal was allowed.
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