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...
ITAT adjudicated a case involving penalty under section 271D for alleged violation of section 269SS. The tribunal determined that the assessee's receipt of cash for immovable property sale, executed before a government registration authority, did not constitute a statutory breach. The tribunal exercised judicial discretion, recognizing the assessee's bonafide belief regarding the applicability of statutory provisions. Considering the technical nature of the alleged violation and following precedential reasoning, the tribunal deleted the penalty imposed under section 271D, emphasizing that statutory obligations must be interpreted with contextual understanding and reasonable interpretation.
ITAT adjudicated a case involving penalty under section 271D for alleged violation of section 269SS. The tribunal determined that the assessee's receipt of cash for immovable property sale, executed before a government registration authority, did not constitute a statutory breach. The tribunal exercised judicial discretion, recognizing the assessee's bonafide belief regarding the applicability of statutory provisions. Considering the technical nature of the alleged violation and following precedential reasoning, the tribunal deleted the penalty imposed under section 271D, emphasizing that statutory obligations must be interpreted with contextual understanding and reasonable interpretation.
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TaxTMI 
TaxTMI 
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