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 271D for alleged acceptance of a cash loan was held unsustainable where the case rested only on a third-party statement recorded in search proceedings and loose papers found at another premises. The assessee consistently denied taking any cash loan, yet the Assessing Officer did not provide the incriminating material, related assessment details, or an opportunity to cross-examine the alleged lender. In the absence of independent corroborative evidence, the allegation was treated as conjecture; loose sheets and random entries were said to have no evidentiary value against a third person unless supported by admissible material and surrounding circumstances. The penalty was deleted.
Penalty under section 271D for alleged acceptance of a cash loan was held unsustainable where the case rested only on a third-party statement recorded in search proceedings and loose papers found at another premises. The assessee consistently denied taking any cash loan, yet the Assessing Officer did not provide the incriminating material, related assessment details, or an opportunity to cross-examine the alleged lender. In the absence of independent corroborative evidence, the allegation was treated as conjecture; loose sheets and random entries were said to have no evidentiary value against a third person unless supported by admissible material and surrounding circumstances. The penalty was deleted.
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