Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The ITAT Delhi held that the levy of penalty u/s 271D without valid satisfaction for alleged violation u/s 269SS is not justified. The AO must record satisfaction in the assessment order u/s 143(3) to initiate penalty proceedings u/s 271D. In this case, the AO failed to record satisfaction for penalty u/s 271D for the relevant assessment years. The tribunal referred to the case law of Jai Laxmi Rice Mills and concluded that penalty u/s 271D was not warranted. Consequently, the penalty imposed u/s 271D for both assessment years was deleted, and the appeals of the assessee were allowed.
The ITAT Delhi held that the levy of penalty u/s 271D without valid satisfaction for alleged violation u/s 269SS is not justified. The AO must record satisfaction in the assessment order u/s 143(3) to initiate penalty proceedings u/s 271D. In this case, the AO failed to record satisfaction for penalty u/s 271D for the relevant assessment years. The tribunal referred to the case law of Jai Laxmi Rice Mills and concluded that penalty u/s 271D was not warranted. Consequently, the penalty imposed u/s 271D for both assessment years was deleted, and the appeals of the assessee were allowed.
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