Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
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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