Split consignment classification treated complementary motorcycle parts as one imported motorcycle, sustaining valuation, confiscation and importer li...
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Section 270A excludes an amount from under-reported income where the taxpayer gives a bona fide explanation and fully discloses material facts needed to support it. Rejection of a claim in quantum proceedings does not itself establish false particulars, concealment, or lack of bona fides. Software-development expenditure and its accounting treatment disclosed in audited financial statements may therefore remain eligible for exclusion where the dispute concerns the debatable legal characterisation of the expenditure as revenue expenditure or capital loss. On the stated facts, the statutory exclusion applied and the penalty was deleted.
Section 270A excludes an amount from under-reported income where the taxpayer gives a bona fide explanation and fully discloses material facts needed to support it. Rejection of a claim in quantum proceedings does not itself establish false particulars, concealment, or lack of bona fides. Software-development expenditure and its accounting treatment disclosed in audited financial statements may therefore remain eligible for exclusion where the dispute concerns the debatable legal characterisation of the expenditure as revenue expenditure or capital loss. On the stated facts, the statutory exclusion applied and the penalty was deleted.
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