Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Penalty under Section 271(1)(c) was held unsustainable where the underlying quantum addition for alleged bogus purchases represented only an estimated profit element and not a definite, proved concealment. The ITAT deleted the penalty for Assessment Year 2010-2011 on the ground that estimated additions alone do not justify penalty. For Assessment Year 2011-2012, the appellate order sustaining penalty was set aside because the assessee's submissions had not been considered; the matter was remanded for fresh adjudication after giving reasonable opportunity and addressing the material placed on record.
Penalty under Section 271(1)(c) was held unsustainable where the underlying quantum addition for alleged bogus purchases represented only an estimated profit element and not a definite, proved concealment. The ITAT deleted the penalty for Assessment Year 2010-2011 on the ground that estimated additions alone do not justify penalty. For Assessment Year 2011-2012, the appellate order sustaining penalty was set aside because the assessee's submissions had not been considered; the matter was remanded for fresh adjudication after giving reasonable opportunity and addressing the material placed on record.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
