Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
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...
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ITAT upheld the assessee's appeal, finding no justifiable basis to reclassify share application money as loans/deposits under Section 269SS. The Tribunal relied on the jurisdictional High Court's precedent, which clarified that share application money does not fall under loan or deposit provisions. Consequently, the penalty under Section 271D was not leviable. The decision affirmed the CIT(A)'s order deleting the penalty, emphasizing strict interpretation of taxing statutes and procedural requirements in penalty proceedings.
ITAT upheld the assessee's appeal, finding no justifiable basis to reclassify share application money as loans/deposits under Section 269SS. The Tribunal relied on the jurisdictional High Court's precedent, which clarified that share application money does not fall under loan or deposit provisions. Consequently, the penalty under Section 271D was not leviable. The decision affirmed the CIT(A)'s order deleting the penalty, emphasizing strict interpretation of taxing statutes and procedural requirements in penalty proceedings.
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