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(2)(b) was deleted where executors could not file the deceased assessee's return before probate was granted. The Tribunal accepted that, under section 270A(6), the explanation was reasonable and bona fide because the delay arose from circumstances beyond the executors' control, including the absence of court appointment and the time taken to obtain probate. It also noted that the obligation on legal heirs or executors to file the return arises only after receipt of the court order appointing them, and the relevant period was covered by the Supreme Court's COVID-related limitation extension. The penalty was therefore unsustainable.
Penalty under section 270A(2)(b) was deleted where executors could not file the deceased assessee's return before probate was granted. The Tribunal accepted that, under section 270A(6), the explanation was reasonable and bona fide because the delay arose from circumstances beyond the executors' control, including the absence of court appointment and the time taken to obtain probate. It also noted that the obligation on legal heirs or executors to file the return arises only after receipt of the court order appointing them, and the relevant period was covered by the Supreme Court's COVID-related limitation extension. The penalty was therefore unsustainable.
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