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...
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Penalty under section 271(1)(c) could not be sustained where the assessee had disclosed all particulars in the return and the claim was only disallowed as a matter of law. Applying CIT v. Reliance Petro Products Ltd., the ITAT held that concealment of income or furnishing of inaccurate particulars is required for penalty, and a mere unsustainable claim for document and stamp charges related to increase in authorised share capital does not meet that test. The penalty was deleted and the assessee's appeal was allowed.
Penalty under section 271(1)(c) could not be sustained where the assessee had disclosed all particulars in the return and the claim was only disallowed as a matter of law. Applying CIT v. Reliance Petro Products Ltd., the ITAT held that concealment of income or furnishing of inaccurate particulars is required for penalty, and a mere unsustainable claim for document and stamp charges related to increase in authorised share capital does not meet that test. The penalty was deleted and the assessee's appeal was allowed.
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