SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
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.
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