Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
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The ITAT held that penalty for TDS default under section 272A(2)(g) was not justified because the assessee had shown reasonable cause, bringing the case within the protection of section 273B. Although the defaults related to different periods and the appeal was not a duplicate, the merits were covered by an earlier order in the assessee's own case on similar facts for the same assessment year. Following that precedent, the Tribunal upheld deletion of the penalty and dismissed the Revenue's appeal.
The ITAT held that penalty for TDS default under section 272A(2)(g) was not justified because the assessee had shown reasonable cause, bringing the case within the protection of section 273B. Although the defaults related to different periods and the appeal was not a duplicate, the merits were covered by an earlier order in the assessee's own case on similar facts for the same assessment year. Following that precedent, the Tribunal upheld deletion of the penalty and dismissed the Revenue's appeal.
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