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...
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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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