Alternative statutory remedy and delay bar GST writ challenges despite pending rectification, while distinct subject matter permits parallel proceedin...
Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
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Penalty under Section 271(1)(c) does not follow merely from a Section 43B disallowance where statutory tax liabilities were not claimed as expenditure, were disclosed in the tax audit report, and rested on a plausible interpretation; a quantum addition alone does not establish inaccurate particulars. Foreign dividend income disclosed in Schedule SI and taxed at the applicable special rate is not concealed merely because it was omitted from the computation summary, where the mismatch was inadvertent and rectification was voluntarily sought before revisionary proceedings. Penalties relating to both items were deleted, and the Revenue's challenge failed.
Penalty under Section 271(1)(c) does not follow merely from a Section 43B disallowance where statutory tax liabilities were not claimed as expenditure, were disclosed in the tax audit report, and rested on a plausible interpretation; a quantum addition alone does not establish inaccurate particulars. Foreign dividend income disclosed in Schedule SI and taxed at the applicable special rate is not concealed merely because it was omitted from the computation summary, where the mismatch was inadvertent and rectification was voluntarily sought before revisionary proceedings. Penalties relating to both items were deleted, and the Revenue's challenge failed.
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