Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
The ITAT examined penalty proceedings u/s 271D regarding alleged cash receipt of property sale consideration. The tribunal found AO and CIT(A)'s presumption of cash payment without explicit documentary evidence was incorrect. The appellate tribunal set aside the penalty order and restored the matter to AO for further investigation to definitively ascertain whether sale consideration was received in cash, contravening sec.269SS. The assessee's appeal was allowed for statistical purposes, requiring the AO to conduct a comprehensive re-examination of the mode of payment and potential statutory violations.
The ITAT examined penalty proceedings u/s 271D regarding alleged cash receipt of property sale consideration. The tribunal found AO and CIT(A)'s presumption of cash payment without explicit documentary evidence was incorrect. The appellate tribunal set aside the penalty order and restored the matter to AO for further investigation to definitively ascertain whether sale consideration was received in cash, contravening sec.269SS. The assessee's appeal was allowed for statistical purposes, requiring the AO to conduct a comprehensive re-examination of the mode of payment and potential statutory violations.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
