Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Penalty under section 271(1)(c) was held unsustainable where the...
Penalty under section 271(1)(c) deleted where income was disclosed in section 153A returns and remaining additions were only estimated or computational.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Penalty under section 271(1)(c) was held unsustainable where the income had already been disclosed in returns filed in response to section 153A notices and accepted in assessment, because such disclosure could not by itself amount to concealment or furnishing inaccurate particulars. The Tribunal also found that the remaining additions were only estimated deemed brokerage adjustments and calculation errors, which did not meet the statutory threshold for penalty. On those facts, the penalties for the relevant assessment years were deleted.
Penalty under section 271(1)(c) was held unsustainable where the income had already been disclosed in returns filed in response to section 153A notices and accepted in assessment, because such disclosure could not by itself amount to concealment or furnishing inaccurate particulars. The Tribunal also found that the remaining additions were only estimated deemed brokerage adjustments and calculation errors, which did not meet the statutory threshold for penalty. On those facts, the penalties for the relevant assessment years were deleted.
Note: It is a system-generated summary and is for quick reference only.