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...
Penalty under section 271(1)(c) could not survive once the related interest disallowance under section 36(1)(iii) had already been deleted in the quantum appeal, because the basis for the penalty no longer existed. On the subsidy issue, the Tribunal treated the capital-versus-revenue characterisation of the grant as a debatable question and held that such a disputed classification did not establish concealment or furnishing of inaccurate particulars. The penalty was therefore deleted in full.
Penalty under section 271(1)(c) could not survive once the related interest disallowance under section 36(1)(iii) had already been deleted in the quantum appeal, because the basis for the penalty no longer existed. On the subsidy issue, the Tribunal treated the capital-versus-revenue characterisation of the grant as a debatable question and held that such a disputed classification did not establish concealment or furnishing of inaccurate particulars. The penalty was therefore deleted in full.
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