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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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 upheld penalty proceedings under section 271D against the assessee for accepting cash loans during FY 2016-17. Evidence from seized documents and statements of Sachin Nahar confirmed cash loans provided to Mantra Properties. The authorized representative failed to rebut the evidence during cross-examination. Despite CIT(A)'s earlier deletion of addition, ITAT ruled that concrete evidence existed through incriminating documents detailing cash loans, interest payments, and corroborative statements. The tribunal determined the penalty was justified, allowing the revenue's appeal and reinstating the penalty levied by JCIT/Addl.CIT under section 271D.
ITAT upheld penalty proceedings under section 271D against the assessee for accepting cash loans during FY 2016-17. Evidence from seized documents and statements of Sachin Nahar confirmed cash loans provided to Mantra Properties. The authorized representative failed to rebut the evidence during cross-examination. Despite CIT(A)'s earlier deletion of addition, ITAT ruled that concrete evidence existed through incriminating documents detailing cash loans, interest payments, and corroborative statements. The tribunal determined the penalty was justified, allowing the revenue's appeal and reinstating the penalty levied by JCIT/Addl.CIT under section 271D.
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