Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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ITAT ruled against penalty under Section 271D for alleged violation of Section 269SS regarding cash transactions in property transfer. The Tribunal held that while Section 269SS applies broadly to property transfers beyond simple buy-sell transactions, it targets actual recipients of funds, not intermediaries. The appellant, acting as a broker, merely facilitated payments between principals and wasn't the true recipient. Additionally, ITAT found reasonable cause under Section 273B, noting the relevant amendment to Section 269SS occurred after the transaction date. The appellant's limited education and role as middleman demonstrated absence of malafide intent. The Tribunal directed deletion of penalty, allowing the appeal.
ITAT ruled against penalty under Section 271D for alleged violation of Section 269SS regarding cash transactions in property transfer. The Tribunal held that while Section 269SS applies broadly to property transfers beyond simple buy-sell transactions, it targets actual recipients of funds, not intermediaries. The appellant, acting as a broker, merely facilitated payments between principals and wasn't the true recipient. Additionally, ITAT found reasonable cause under Section 273B, noting the relevant amendment to Section 269SS occurred after the transaction date. The appellant's limited education and role as middleman demonstrated absence of malafide intent. The Tribunal directed deletion of penalty, allowing the appeal.
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