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 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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