Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
ITAT held that penalty for failure to obtain tax audit was not automatic where the assessee showed reasonable cause under section 271B. The society's initial year of operations, lack of professional guidance and infrastructure, rural background, and bona fide belief that audit under the Co-operative Societies Act was sufficient were accepted, especially as the explanation was neither false nor mala fide. The nil-income assessment and absence of adverse inference of suppression supported the genuineness of the explanation. On these facts, the Tribunal found the penalty unsustainable and deleted it.
ITAT held that penalty for failure to obtain tax audit was not automatic where the assessee showed reasonable cause under section 271B. The society's initial year of operations, lack of professional guidance and infrastructure, rural background, and bona fide belief that audit under the Co-operative Societies Act was sufficient were accepted, especially as the explanation was neither false nor mala fide. The nil-income assessment and absence of adverse inference of suppression supported the genuineness of the explanation. On these facts, the Tribunal found the penalty unsustainable and deleted it.
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