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...
Cash consideration receivable, whether as advance or otherwise, for transfer of immovable property falls within "specified sum" and is governed by section 269SS; the contention that section 269ST exclusively applied was rejected. However, penalty under section 271D could not be sustained for an assessment year in which no cash consideration was received. As the relevant receipts occurred in an earlier financial year, the penalty levied for AY 2017-18 was held invalid and deleted. The Tribunal also noted that part of the receipts preceded the amendment extending section 269SS to specified sums connected with immovable property transfers.
Cash consideration receivable, whether as advance or otherwise, for transfer of immovable property falls within "specified sum" and is governed by section 269SS; the contention that section 269ST exclusively applied was rejected. However, penalty under section 271D could not be sustained for an assessment year in which no cash consideration was received. As the relevant receipts occurred in an earlier financial year, the penalty levied for AY 2017-18 was held invalid and deleted. The Tribunal also noted that part of the receipts preceded the amendment extending section 269SS to specified sums connected with immovable property transfers.
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