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 under section 271D was quashed because the assessment order did not record the Assessing Officer's satisfaction that the assessee had committed a contravention attracting that penalty. The Tribunal held that such recorded satisfaction in the body of the assessment order is a jurisdictional prerequisite for valid initiation of penalty proceedings; a mere reference to penalty under section 271(1)(c) was insufficient. In the absence of that foundation, the Joint Commissioner lacked jurisdiction to proceed, the penalty order was invalid, and the appellate order sustaining it was set aside.
Penalty under section 271D was quashed because the assessment order did not record the Assessing Officer's satisfaction that the assessee had committed a contravention attracting that penalty. The Tribunal held that such recorded satisfaction in the body of the assessment order is a jurisdictional prerequisite for valid initiation of penalty proceedings; a mere reference to penalty under section 271(1)(c) was insufficient. In the absence of that foundation, the Joint Commissioner lacked jurisdiction to proceed, the penalty order was invalid, and the appellate order sustaining it was set aside.
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