Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Penalty levied u/s 271D - assessee has availed cash loan in contravention of provision of section 269SS - Assessee has submitted that though the assessee has initially availed loans from close relatives, which were subsequently the loans, were treated as gift and credited to his capital account, therefore, levy of penalty under section 271D of the Act is unwarranted - The Tribunal found the explanations offered by the appellant reasonable, especially considering the confirmation letters from the lenders, and the circumstances surrounding the transactions. Accordingly, ITAT directed the AO to delete the penalty.
Penalty levied u/s 271D - assessee has availed cash loan in contravention of provision of section 269SS - Assessee has submitted that though the assessee has initially availed loans from close relatives, which were subsequently the loans, were treated as gift and credited to his capital account, therefore, levy of penalty under section 271D of the Act is unwarranted - The Tribunal found the explanations offered by the appellant reasonable, especially considering the confirmation letters from the lenders, and the circumstances surrounding the transactions. Accordingly, ITAT directed the AO to delete the penalty.
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