Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Offence u/s 276CC - petitioner prime facie found that the non-filing of the return was wilfull - Economic Offences - The petitioner's argument that the tax liability was covered by Tax Deducted at Source (TDS) was refuted, as the TDS amount was insufficient. - The High court emphasized the statutory presumption u/s 278E, shifting the burden onto the petitioner to prove absence of wilfulness. - High court dismissed the petitioner's appeal and directed the lower court to proceed with the proceedings, with a timeline for completion.
Offence u/s 276CC - petitioner prime facie found that the non-filing of the return was wilfull - Economic Offences - The petitioner's argument that the tax liability was covered by Tax Deducted at Source (TDS) was refuted, as the TDS amount was insufficient. - The High court emphasized the statutory presumption u/s 278E, shifting the burden onto the petitioner to prove absence of wilfulness. - High court dismissed the petitioner's appeal and directed the lower court to proceed with the proceedings, with a timeline for completion.
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