Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
Penalty under section 270A could not be adjudicated because the quantum addition forming its basis had already been restored for fresh consideration under the applicable double taxation avoidance agreement. With the underlying addition no longer final, the penalty appeal was premature. The matter was therefore sent back for fresh decision by the Assessing Officer, who was directed to consider whether penalty proceedings should be initiated only after the outcome of the quantum proceedings.
Penalty under section 270A could not be adjudicated because the quantum addition forming its basis had already been restored for fresh consideration under the applicable double taxation avoidance agreement. With the underlying addition no longer final, the penalty appeal was premature. The matter was therefore sent back for fresh decision by the Assessing Officer, who was directed to consider whether penalty proceedings should be initiated only after the outcome of the quantum proceedings.
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