A massive delay in filing BEN-2 for significant beneficial ownership led to maximum penalties. The authority held that prolonged non-compliance attracts strict penal consequences.
The ITAT held that the PCIT cannot invoke revisionary powers when the same issue is already pending before the appellate authority. The case involved share transaction additions treated as penny stock.
The Supreme Court declined to recall its earlier order, effectively upholding the High Court ruling that TDS was not applicable on payments for imported Business Information Reports. The decision affirms reliance on consistent AAR rulings.
The Bombay High Court upheld ITAT’s ruling that payments for Business Information Reports did not attract TDS under Section 195. The decision relied on consistent AAR rulings on identical facts.
The Court held that once a resolution plan is approved, prior tax liabilities stand extinguished. Reassessment under Section 148 was therefore unsustainable.
The High Court held that once a resolution plan under IBC extinguishes prior tax liabilities, reassessment cannot be initiated. The notice under Section 148 was set aside. The ruling confirms that extinguished claims cannot be revived through reassessment.
