Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
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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