Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Cash-payment disallowance under section 40A(3) depends on whether payments exceeding the prescribed daily limit were made to a single person, not merely on a voucher exceeding that limit. A consolidated voucher may record separate payments to multiple persons, each within the limit, and therefore may not establish a contravention. Supporting material omitted by an erstwhile tax consultant was admitted as additional evidence because the first appellate order had been passed without it. The ex parte appellate order and cash-payment disallowance were set aside and remitted to the Assessing Officer for verification and fresh adjudication, with all contentions left open.
Cash-payment disallowance under section 40A(3) depends on whether payments exceeding the prescribed daily limit were made to a single person, not merely on a voucher exceeding that limit. A consolidated voucher may record separate payments to multiple persons, each within the limit, and therefore may not establish a contravention. Supporting material omitted by an erstwhile tax consultant was admitted as additional evidence because the first appellate order had been passed without it. The ex parte appellate order and cash-payment disallowance were set aside and remitted to the Assessing Officer for verification and fresh adjudication, with all contentions left open.
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