Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Addition u/s 69A - Source of Cash deposit - Assessee contended that same is received in advance against the sale of property - Levy of penalty u/s 271D - The ITAT held that, on one hand when the impugned cash receipts are characterized as assessee’s own money the same, on the other hand cannot be a specified sum received from someone else in contravention to provisions of section 269SS, therefore, the very foundation and prerequisite to bring such amount within the realm of section 269SS was lost. - Thus ITAT deleted the penalty on this ground. However, the lelvy penalty, on the issue of repayment of loan to financer in cash, got confirmed.
Addition u/s 69A - Source of Cash deposit - Assessee contended that same is received in advance against the sale of property - Levy of penalty u/s 271D - The ITAT held that, on one hand when the impugned cash receipts are characterized as assessee’s own money the same, on the other hand cannot be a specified sum received from someone else in contravention to provisions of section 269SS, therefore, the very foundation and prerequisite to bring such amount within the realm of section 269SS was lost. - Thus ITAT deleted the penalty on this ground. However, the lelvy penalty, on the issue of repayment of loan to financer in cash, got confirmed.
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