Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
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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