Tuesday, May 29, 2012

PENALTY IS DISCRETIONARY NOT MANDATORY

Shri P V Ramana Reddy Vs ITO, Hyderabad
Income Tax - Section 271(1)(C) - Whether provisions of section 271(1)(C) are discretionary and hence the same are to be exercised in a liberal manner - Whether AO is required to be more liberal particularly in cases where the additions are confirmed as a result of difference of opinion. - Assessee's appeal allowed: HYDERABAD ITAT

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Indirect Transfer on Liquidation of a Foreign Holding Company

1. Introduction Cross-border investment structures often employ intermediate holding companies in jurisdictions like the Cayman Islands. A c...