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Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
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Cash repayment of a family loan between spouses did not justify penalty under section 271E where the loan was fully explained, used for the benefit of the family, and gave rise to no addition. The Tribunal treated both the husband-wife loan transaction and the partial repayment to the wife as family-benefit transactions, following a co-ordinate Bench decision. It held that these circumstances established reasonable cause and made the penalty unsustainable. The penalty was therefore deleted and the appeal was allowed.
Cash repayment of a family loan between spouses did not justify penalty under section 271E where the loan was fully explained, used for the benefit of the family, and gave rise to no addition. The Tribunal treated both the husband-wife loan transaction and the partial repayment to the wife as family-benefit transactions, following a co-ordinate Bench decision. It held that these circumstances established reasonable cause and made the penalty unsustainable. The penalty was therefore deleted and the appeal was allowed.
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