Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Pre-trial bail granted where custodial period, documentary prosecution, and magistrate-triable offence favor release subject to surety and no witness ...
Allowability of Salary Exemptions: Form 16 entries can substantiate HRA and other salary exemptions, and home loan interest is deductible for a self-o...
The ITAT held that penalty under section 271(1)(c) was unsustainable because the dispute concerned only the head of income and the allowability of deduction on disclosed facts, not concealment or furnishing of inaccurate particulars. The assessee's claim for full section 54 relief was accepted on the merits, and the joint reinvestment with her son had been disclosed to the department. Relying on Manjunatha Cotton and Reliance Petroproducts, the Tribunal held that a disallowed claim or a claim under a different head does not by itself justify penalty. The penalty was deleted.
The ITAT held that penalty under section 271(1)(c) was unsustainable because the dispute concerned only the head of income and the allowability of deduction on disclosed facts, not concealment or furnishing of inaccurate particulars. The assessee's claim for full section 54 relief was accepted on the merits, and the joint reinvestment with her son had been disclosed to the department. Relying on Manjunatha Cotton and Reliance Petroproducts, the Tribunal held that a disallowed claim or a claim under a different head does not by itself justify penalty. The penalty was deleted.
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