Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Penalty for accepting cash sale consideration under section 271D was examined in a co-owned property transaction involving an alleged contravention of section 269SS. The relevant circumstances included disclosure of the full sale consideration for taxation after receipt of cash and the absence of penalty against a co-owner participating in the same transaction. Applying the coordinate Bench approach on identical facts, the penalty was deleted. The discussion treats subsequent tax disclosure, comparable treatment of co-owners, and reasonable cause as material considerations in determining whether a cash-acceptance penalty should stand.
Penalty for accepting cash sale consideration under section 271D was examined in a co-owned property transaction involving an alleged contravention of section 269SS. The relevant circumstances included disclosure of the full sale consideration for taxation after receipt of cash and the absence of penalty against a co-owner participating in the same transaction. Applying the coordinate Bench approach on identical facts, the penalty was deleted. The discussion treats subsequent tax disclosure, comparable treatment of co-owners, and reasonable cause as material considerations in determining whether a cash-acceptance penalty should stand.
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