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Confirmation of addition by tribunal does not mean concealment of income or inaccurate furnishing of particulars of income

The penalty proceedings and the assessment proceedings both are different. Explanation 1to section 271(1)(c) in respect of any fact relating to the computation of total income states that the amount added or disallowed in computing the total income of an assessee shall be deemed to be the income in respect of which particulars have been concealed. This deeming provision for concealment is not absolute one.
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