Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
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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