Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
Customs Broker licence proceedings require accurate procedural facts before delay or natural-justice findings can justify setting aside regulatory act...
Provisional assessment finalisation must precede export duty recovery, while redemption fine fails for goods already exported and unavailable for conf...
Recording of satisfaction in the assessment order is a mandatory pre-condition for initiating penalty under section 271D where the alleged violation concerns section 269SS. The Tribunal held that the additional legal ground could be examined on the existing record because it went to the root of the penalty validity. As the assessment order accepted the assessee's explanation for the cash deposits and did not record any satisfaction for penalty initiation, the penalty proceedings could not be sustained. The penalty order was quashed and the assessee's appeal was allowed.
Recording of satisfaction in the assessment order is a mandatory pre-condition for initiating penalty under section 271D where the alleged violation concerns section 269SS. The Tribunal held that the additional legal ground could be examined on the existing record because it went to the root of the penalty validity. As the assessment order accepted the assessee's explanation for the cash deposits and did not record any satisfaction for penalty initiation, the penalty proceedings could not be sustained. The penalty order was quashed and the assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
