Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Disciplinary proportionality requires penalties for Authorised Representative misconduct to match proven harm, leading to reconsideration of registrat...
Revision under section 263 cannot rest solely on an Assessing Officer's failure to record satisfaction or initiate penalty for alleged cash-transaction violations of section 269SS. It requires both an erroneous assessment order and prejudice to Revenue. Penalty under section 271D is independent of assessment proceedings and, under the applicable statutory scheme, falls within the Joint Commissioner's competence. The limitation governing that penalty cannot be bypassed by setting aside a completed assessment to create a fresh penalty foundation, particularly where the underlying transactions admit two plausible views.
Revision under section 263 cannot rest solely on an Assessing Officer's failure to record satisfaction or initiate penalty for alleged cash-transaction violations of section 269SS. It requires both an erroneous assessment order and prejudice to Revenue. Penalty under section 271D is independent of assessment proceedings and, under the applicable statutory scheme, falls within the Joint Commissioner's competence. The limitation governing that penalty cannot be bypassed by setting aside a completed assessment to create a fresh penalty foundation, particularly where the underlying transactions admit two plausible views.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
