Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
Recording of satisfaction in the assessment order is treated as a jurisdictional prerequisite for initiating penalty for cash receipts in contravention of the statutory banking-route rule; a vague reference to possible penalty proceedings is insufficient, and the defect cannot be cured later in the notice, penalty order or appeal. The Tribunal also held that the alleged contravention must be proved with independent and cogent evidence of the payer, date, amount and statutory threshold breach. Rejected books, estimated income and an uncorroborated admission of additional income were not enough. On that basis, the penalty was held unsustainable and deleted.
Recording of satisfaction in the assessment order is treated as a jurisdictional prerequisite for initiating penalty for cash receipts in contravention of the statutory banking-route rule; a vague reference to possible penalty proceedings is insufficient, and the defect cannot be cured later in the notice, penalty order or appeal. The Tribunal also held that the alleged contravention must be proved with independent and cogent evidence of the payer, date, amount and statutory threshold breach. Rejected books, estimated income and an uncorroborated admission of additional income were not enough. On that basis, the penalty was held unsustainable and deleted.
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