Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
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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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