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...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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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