Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Penalty u/s 271D / 271E - violation of provisions of Sec.269SS and 269T - basis of presumption u/s 132(4A) - Period of limitation - The Tribunal found that the penalty proceedings were not validly initiated due to the lack of satisfaction recorded in the assessment order regarding the violation of provisions of Sec.269SS. - It determined that the delay in moving the proposal for penalty proceedings after the conclusion of assessment proceedings was in violation of the CBDT Circular.
Penalty u/s 271D / 271E - violation of provisions of Sec.269SS and 269T - basis of presumption u/s 132(4A) - Period of limitation - The Tribunal found that the penalty proceedings were not validly initiated due to the lack of satisfaction recorded in the assessment order regarding the violation of provisions of Sec.269SS. - It determined that the delay in moving the proposal for penalty proceedings after the conclusion of assessment proceedings was in violation of the CBDT Circular.
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