Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
The ITAT set aside a penalty of Rs. 15 lakhs imposed under section 271D for alleged violation of section 269SS. The Tribunal found that the loan amount was disbursed through banking channels and duly confirmed by both the NBFC and the concerned party. The ITAT held that section 269SS applies only to actual acceptance of money and not to liabilities recorded through journal entries, as the legislative intent is to prevent cash transactions. The provision is restricted to monetary transactions and does not extend to cases where debt or liability arises merely through book entries. Following precedents from the Bombay HC, Delhi HC, and other judicial authorities, the Tribunal concluded the transaction was outside the ambit of section 269SS and deleted the penalty.
The ITAT set aside a penalty of Rs. 15 lakhs imposed under section 271D for alleged violation of section 269SS. The Tribunal found that the loan amount was disbursed through banking channels and duly confirmed by both the NBFC and the concerned party. The ITAT held that section 269SS applies only to actual acceptance of money and not to liabilities recorded through journal entries, as the legislative intent is to prevent cash transactions. The provision is restricted to monetary transactions and does not extend to cases where debt or liability arises merely through book entries. Following precedents from the Bombay HC, Delhi HC, and other judicial authorities, the Tribunal concluded the transaction was outside the ambit of section 269SS and deleted the penalty.
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TaxTMI 
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