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 for failure to furnish a tax audit report was deleted where consistent past and subsequent treatment of bank interest as income from other sources supported a bona fide belief that the audit requirement was not attracted. The assessee had disclosed the interest uniformly in earlier and later years, and that treatment had been accepted in section 143(1) intimations. As the Revenue produced no material of deliberate or conscious default, the failure was treated as covered by reasonable cause, making the penalty unsustainable.
Penalty for failure to furnish a tax audit report was deleted where consistent past and subsequent treatment of bank interest as income from other sources supported a bona fide belief that the audit requirement was not attracted. The assessee had disclosed the interest uniformly in earlier and later years, and that treatment had been accepted in section 143(1) intimations. As the Revenue produced no material of deliberate or conscious default, the failure was treated as covered by reasonable cause, making the penalty unsustainable.
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