Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Penalty under section 271DA required a clear jurisdictional foundation in the assessment order itself, including recorded satisfaction identifying the alleged cash receipt and the ingredients of section 269ST; a bare reference to penalty proceedings was insufficient, so jurisdiction failed and the penalty order was quashed. On merits, contravention had to be proved by cogent corroborative material showing person-wise, transaction-wise or event-wise receipt beyond the statutory threshold; uncorroborated tally data, statements and estimated income from rejected books did not discharge the Revenue's burden, so the penalty was deleted.
Penalty under section 271DA required a clear jurisdictional foundation in the assessment order itself, including recorded satisfaction identifying the alleged cash receipt and the ingredients of section 269ST; a bare reference to penalty proceedings was insufficient, so jurisdiction failed and the penalty order was quashed. On merits, contravention had to be proved by cogent corroborative material showing person-wise, transaction-wise or event-wise receipt beyond the statutory threshold; uncorroborated tally data, statements and estimated income from rejected books did not discharge the Revenue's burden, so the penalty was deleted.
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