Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Penalty u/s 271D & 271E - allegation of cash loan having been taken/repaid - The ITAT underscored the principle that penalties under Sections 271D and 271E for violations of Sections 269SS and 269T are not applicable when the existence of the transactions (cash loans taken and repaid) is itself disputed. Furthermore, it highlighted the importance of adhering to principles of natural justice, including the right to cross-examine evidence used against the assessee.
Penalty u/s 271D & 271E - allegation of cash loan having been taken/repaid - The ITAT underscored the principle that penalties under Sections 271D and 271E for violations of Sections 269SS and 269T are not applicable when the existence of the transactions (cash loans taken and repaid) is itself disputed. Furthermore, it highlighted the importance of adhering to principles of natural justice, including the right to cross-examine evidence used against the assessee.
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