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Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
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Penalty under section 270A was deleted because the assessee had made a deduction claim under section 80GGC, and the Assessing Officer had examined that claim; mere disallowance of the deduction did not, on these facts, establish under-reporting or misreporting. The Tribunal also held the penalty order unsustainable because it did not specify the applicable limb of section 270A or set out the particulars required to satisfy sub-section (9). As the statutory basis and necessary ingredients were not properly identified, the penalty could not be sustained.
Penalty under section 270A was deleted because the assessee had made a deduction claim under section 80GGC, and the Assessing Officer had examined that claim; mere disallowance of the deduction did not, on these facts, establish under-reporting or misreporting. The Tribunal also held the penalty order unsustainable because it did not specify the applicable limb of section 270A or set out the particulars required to satisfy sub-section (9). As the statutory basis and necessary ingredients were not properly identified, the penalty could not be sustained.
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