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...
Penalty under section 270A was deleted where the assessee claimed deduction for Health and Education Cess on a bona fide legal view supported by existing High Court precedents, fully disclosed the claim in the return, and voluntarily withdrew the claim during assessment after a retrospective statutory explanation was introduced. Applying the principle that a claim made on a debatable legal interpretation with full disclosure and without concealment does not attract penalty, the case falls within the non-penalising scope of the relevant proviso, leading to deletion of the penalty.
Penalty under section 270A was deleted where the assessee claimed deduction for Health and Education Cess on a bona fide legal view supported by existing High Court precedents, fully disclosed the claim in the return, and voluntarily withdrew the claim during assessment after a retrospective statutory explanation was introduced. Applying the principle that a claim made on a debatable legal interpretation with full disclosure and without concealment does not attract penalty, the case falls within the non-penalising scope of the relevant proviso, leading to deletion of the penalty.
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