Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Reason to believe as an essential ingredient for imposing a penalty under section 112(b) is examined, with emphasis on corroboration failures and circumstantial indicators permitting an inference of prior knowledge rather than innocent carriage; the account's unverifiable intermediary, non traceable contact details and voluntary no objection to seizure supported that inference, sustaining the legal basis for penalty. The article also explains that judicial discretion may moderate penalty quantum on humanitarian and equitable grounds where confiscation and prosecution remain in place, resulting in reduced monetary penalties.
Reason to believe as an essential ingredient for imposing a penalty under section 112(b) is examined, with emphasis on corroboration failures and circumstantial indicators permitting an inference of prior knowledge rather than innocent carriage; the account's unverifiable intermediary, non traceable contact details and voluntary no objection to seizure supported that inference, sustaining the legal basis for penalty. The article also explains that judicial discretion may moderate penalty quantum on humanitarian and equitable grounds where confiscation and prosecution remain in place, resulting in reduced monetary penalties.
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