Tax collection at source on purchases removes duplicate withholding obligation, while trade-creditor evidence requires verification before unexplained...
Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
Commodity derivatives position limits adopt revised breach penalties, broad commodity criteria, and client open-position limits based on deliverable s...
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Penalty under section 271(1)(c) cannot rest on a disallowance of business interest on secured promissory notes once the underlying quantum disallowance has been reversed. Interest on those notes was treated as incurred for business purposes and therefore not deductible only on an unsustainable basis. The Tribunal's deletion of penalty was upheld because the issue was initially debatable and the quantum position later attained finality. With no surviving basis for the disallowance, the penalty could not continue, and the Revenue's appeals were dismissed.
Penalty under section 271(1)(c) cannot rest on a disallowance of business interest on secured promissory notes once the underlying quantum disallowance has been reversed. Interest on those notes was treated as incurred for business purposes and therefore not deductible only on an unsustainable basis. The Tribunal's deletion of penalty was upheld because the issue was initially debatable and the quantum position later attained finality. With no surviving basis for the disallowance, the penalty could not continue, and the Revenue's appeals were dismissed.
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