Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Penalty for non-compliance with statutory notices under section 271(1)(b) is not sustainable where the assessee establishes reasonable cause under section 273B. The Tribunal accepted that the assessee was not a regular taxpayer, was unaware of the income-tax proceedings and portal-related compliance, and learnt of the ex parte assessment only after demand was raised. It also noted that the quantum matter had already been restored to the AO. On these facts, the defaults in responding to the notices were treated as sufficiently explained, and the penalty was deleted.
Penalty for non-compliance with statutory notices under section 271(1)(b) is not sustainable where the assessee establishes reasonable cause under section 273B. The Tribunal accepted that the assessee was not a regular taxpayer, was unaware of the income-tax proceedings and portal-related compliance, and learnt of the ex parte assessment only after demand was raised. It also noted that the quantum matter had already been restored to the AO. On these facts, the defaults in responding to the notices were treated as sufficiently explained, and the penalty was deleted.
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