Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
ITAT refused to condone a 1023-day delay in filing the quantum appeal, holding that a conscious decision not to pursue the statutory remedy after weighing tax effect and litigation cost was not sufficient cause. The quantum appeal was therefore dismissed as time-barred without examining the merits. On penalty, the Tribunal held that disallowance of a CSR-related donation claim under section 80G did not by itself establish misreporting under section 270A. As no suppression of facts, false entries, or fabricated evidence was found, and the assessee had disclosed all primary facts, the explanation was bona fide and protected by section 270A(6)(a). The penalty was deleted.
ITAT refused to condone a 1023-day delay in filing the quantum appeal, holding that a conscious decision not to pursue the statutory remedy after weighing tax effect and litigation cost was not sufficient cause. The quantum appeal was therefore dismissed as time-barred without examining the merits. On penalty, the Tribunal held that disallowance of a CSR-related donation claim under section 80G did not by itself establish misreporting under section 270A. As no suppression of facts, false entries, or fabricated evidence was found, and the assessee had disclosed all primary facts, the explanation was bona fide and protected by section 270A(6)(a). The penalty was deleted.
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