Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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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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