Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Membership-consent thresholds for oppression petitions are satisfied by unchallenged voter-list consents, while unsupported forgery claims require pro...
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.
Note: It is a system-generated summary and is for quick reference only.