Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
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Reasonable cause under Section 273B operates to preclude imposition of penalties under Sections 271D and 271E where the assessee demonstrably shows bona fide belief and genuineness of transactions; thus deposit of cash in bank accounts, explained as bona fide and not motivated to avoid tax, furnished a reasonable cause and led to relief from penalties. The tribunal applied the ordinary prudence standard for 'reasonable cause'-a cause beyond the assessee's control, without negligence or lack of bona fides-and allowed the appeal on that basis.
Reasonable cause under Section 273B operates to preclude imposition of penalties under Sections 271D and 271E where the assessee demonstrably shows bona fide belief and genuineness of transactions; thus deposit of cash in bank accounts, explained as bona fide and not motivated to avoid tax, furnished a reasonable cause and led to relief from penalties. The tribunal applied the ordinary prudence standard for 'reasonable cause'-a cause beyond the assessee's control, without negligence or lack of bona fides-and allowed the appeal on that basis.
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