Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
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The ITAT deleted penalty for alleged unexplained cash receipts, holding that the assessee's explanation that estimated income was offered and tax was paid to buy peace and avoid prolonged litigation was plausible on the facts. The Tribunal also noted that, on a similar explanation, the AO had already dropped penalty proceedings for under-reporting of income. On an overall review of the digital material and surrounding record, it found the evidence insufficient to justify sustaining the penalty for alleged cash transactions.
The ITAT deleted penalty for alleged unexplained cash receipts, holding that the assessee's explanation that estimated income was offered and tax was paid to buy peace and avoid prolonged litigation was plausible on the facts. The Tribunal also noted that, on a similar explanation, the AO had already dropped penalty proceedings for under-reporting of income. On an overall review of the digital material and surrounding record, it found the evidence insufficient to justify sustaining the penalty for alleged cash transactions.
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