Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
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...
Penalty for alleged cash receipt cannot be imposed without demonstrative evidence establishing the actual cash transaction required for the cash-receipt restriction. Material showed a cash receipt only to a limited extent, while the balance was inferred conjecturally. Because the Revenue did not establish the factual basis for invoking section 269SS, deletion of the section 271D penalty was confirmed and its appeal dismissed.
Penalty for alleged cash receipt cannot be imposed without demonstrative evidence establishing the actual cash transaction required for the cash-receipt restriction. Material showed a cash receipt only to a limited extent, while the balance was inferred conjecturally. Because the Revenue did not establish the factual basis for invoking section 269SS, deletion of the section 271D penalty was confirmed and its appeal dismissed.
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