Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
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Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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ITAT held that cash receipt of Rs. 7 lakhs for immovable property sale did not violate section 269SS. The unregistered agreement to sale, which subsequently culminated in a sale deed, was deemed valid. The department failed to verify the cash payment details or provide cogent reasons for rejecting the assessee's claim. No substantive evidence demonstrated a violation of statutory provisions. The tribunal found no merit in the penalty order and directed the Assessing Officer to delete the penalty. The appeal was allowed, with the CIT(A)'s procedural inconsistencies regarding appeal filing date also noted and dismissed.
ITAT held that cash receipt of Rs. 7 lakhs for immovable property sale did not violate section 269SS. The unregistered agreement to sale, which subsequently culminated in a sale deed, was deemed valid. The department failed to verify the cash payment details or provide cogent reasons for rejecting the assessee's claim. No substantive evidence demonstrated a violation of statutory provisions. The tribunal found no merit in the penalty order and directed the Assessing Officer to delete the penalty. The appeal was allowed, with the CIT(A)'s procedural inconsistencies regarding appeal filing date also noted and dismissed.
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