Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Customs valuation and classification require comparable evidence and assessment of imported goods in their actual condition, invalidating related pena...
After the 01.04.1989 amendment, delayed payment of self-assessment tax under section 140A(3) no longer attracted penalty; the provision treated the assessee as in default only for recovery of unpaid tax and interest. In the absence of any corresponding expansion of section 221(1), penalty could not be imposed for such default under section 140A(3) read with section 221(1). The Tribunal therefore held the penalty unsustainable in law and directed its deletion. The issue of sufficient cause for the delay became academic once statutory authority for the penalty itself was lacking.
After the 01.04.1989 amendment, delayed payment of self-assessment tax under section 140A(3) no longer attracted penalty; the provision treated the assessee as in default only for recovery of unpaid tax and interest. In the absence of any corresponding expansion of section 221(1), penalty could not be imposed for such default under section 140A(3) read with section 221(1). The Tribunal therefore held the penalty unsustainable in law and directed its deletion. The issue of sufficient cause for the delay became academic once statutory authority for the penalty itself was lacking.
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