Clubbing of income from gifted property failed where the claim surfaced after reassessment limitation, sustaining capital-gains assessment in spouse's...
Employee stock-option discount qualifies as revenue expenditure, while royalty and service comparables require reliable functional and transactional b...
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Jurisdictional satisfaction for penalty under section 271(1)(c) must be recorded during assessment, including a direction to initiate penalty under that provision where deemed satisfaction is invoked. Initiation under section 271AAC, a distinct provision with separate conditions and consequences, cannot support a later notice or penalty under section 271(1)(c). A subsequent penalty order cannot amend the assessment order or retrospectively create foundational jurisdiction. The penalty was therefore deleted, while the quantum appeal remained for independent determination on merits.
Jurisdictional satisfaction for penalty under section 271(1)(c) must be recorded during assessment, including a direction to initiate penalty under that provision where deemed satisfaction is invoked. Initiation under section 271AAC, a distinct provision with separate conditions and consequences, cannot support a later notice or penalty under section 271(1)(c). A subsequent penalty order cannot amend the assessment order or retrospectively create foundational jurisdiction. The penalty was therefore deleted, while the quantum appeal remained for independent determination on merits.
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