Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
The assessee failed to repay a loan to M/s. Mahindra & Mahindra Financial Services Pvt. Ltd., leading to the auctioning of a car during the assessment year. The successful bidder in the auction made a cash payment directly to M/s. Mahindra & Mahindra Financial Services Pvt. Ltd.'s bank account to clear the loan. The Appellate Tribunal held that since the cash payment was made by the bidder and not the assessee, the assessee cannot be penalized u/s 271E for violating section 269T's provisions regarding cash repayment of a loan. Consequently, the assessee's appeal against the penalty was allowed.
The assessee failed to repay a loan to M/s. Mahindra & Mahindra Financial Services Pvt. Ltd., leading to the auctioning of a car during the assessment year. The successful bidder in the auction made a cash payment directly to M/s. Mahindra & Mahindra Financial Services Pvt. Ltd.'s bank account to clear the loan. The Appellate Tribunal held that since the cash payment was made by the bidder and not the assessee, the assessee cannot be penalized u/s 271E for violating section 269T's provisions regarding cash repayment of a loan. Consequently, the assessee's appeal against the penalty was allowed.
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