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Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
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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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