Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Penalty u/s 271D & 271E - default committed in violation of section 269SS & 269T - Reliance on search proceeding documents - Transactions being mere book entries - Following the judgement of Supreme Court, the Tribunal held that, the expression “money” means currency/cash. Therefore, very essential ingredient to constitute a default within the meaning of 269SS or 269T is that whether there is movement of money. Mere book entries alone, during the course of training, cannot entail a default of taking or repaying the loan in cash, unless it is established that Moneys moved from one person to another person, which is in the nature of loans or deposits” - CIT(A) rightly deleted the penalties.
Penalty u/s 271D & 271E - default committed in violation of section 269SS & 269T - Reliance on search proceeding documents - Transactions being mere book entries - Following the judgement of Supreme Court, the Tribunal held that, the expression “money” means currency/cash. Therefore, very essential ingredient to constitute a default within the meaning of 269SS or 269T is that whether there is movement of money. Mere book entries alone, during the course of training, cannot entail a default of taking or repaying the loan in cash, unless it is established that Moneys moved from one person to another person, which is in the nature of loans or deposits” - CIT(A) rightly deleted the penalties.
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