Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Penalty under section 271D for alleged section 269SS violation was held time-barred where the Assessing Officer had recorded satisfaction and referred the matter for penalty during assessment, because limitation under section 275(1)(c) ran from the end of that month and was not extended by the later penalty notice. The penalty was also found unsustainable on merits: the receipt was genuine sale consideration for agricultural land, the assessee showed reasonable cause under section 273B, and the bona fide belief that such a transaction would not attract section 269SS negatived penalty. The levy was therefore quashed.
Penalty under section 271D for alleged section 269SS violation was held time-barred where the Assessing Officer had recorded satisfaction and referred the matter for penalty during assessment, because limitation under section 275(1)(c) ran from the end of that month and was not extended by the later penalty notice. The penalty was also found unsustainable on merits: the receipt was genuine sale consideration for agricultural land, the assessee showed reasonable cause under section 273B, and the bona fide belief that such a transaction would not attract section 269SS negatived penalty. The levy was therefore quashed.
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