Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
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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