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506 orders · Page 6 of 11
The Tribunal held that the assessee had reasonable cause for non-compliance due to the detention of a key person and the overwhelming number of group assessments. The Tribunal also noted that the demand in quantum proceedings was reduced to nil, rendering the non-compliance technical.
The Tribunal held that the outstanding liabilities were not irrevocably ceased as they were acknowledged and under negotiation, thus not taxable under Section 41(1). It also held that Section 14A disallowance is not applicable when no exempt income is earned in the relevant year.