Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
Penalty for cash receipts is attracted only when the receipt falls within one of the three statutory situations under section 269ST: receipt from a person in a day, receipt for a single transaction, or receipt relating to one event or occasion. The note explains that admitted cash sales, or an assessment completed by estimating profit on those sales, are not enough by themselves; the penalty order must record facts showing the specific statutory breach. In the absence of such findings, levy of penalty under section 271DA is unjustified, and the same reasoning applies where the facts and issue are identical across years.
Penalty for cash receipts is attracted only when the receipt falls within one of the three statutory situations under section 269ST: receipt from a person in a day, receipt for a single transaction, or receipt relating to one event or occasion. The note explains that admitted cash sales, or an assessment completed by estimating profit on those sales, are not enough by themselves; the penalty order must record facts showing the specific statutory breach. In the absence of such findings, levy of penalty under section 271DA is unjustified, and the same reasoning applies where the facts and issue are identical across years.
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