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...
Penalty under section 271D was held unsustainable where no assessment order existed in the assessee's case and, therefore, no prior recorded satisfaction could be discerned regarding the alleged section 269SS default. The Tribunal followed its earlier view in Umakant Sharma and held that initiation and levy of penalty without assessment proceedings in the assessee's case was legally invalid. The impugned penalty was directed to be deleted.
Penalty under section 271D was held unsustainable where no assessment order existed in the assessee's case and, therefore, no prior recorded satisfaction could be discerned regarding the alleged section 269SS default. The Tribunal followed its earlier view in Umakant Sharma and held that initiation and levy of penalty without assessment proceedings in the assessee's case was legally invalid. The impugned penalty was directed to be deleted.
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