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...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
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 dismissed the appeal of Appellant-Revenue and upheld the CIT(A)'s deletion of penalty under s.271D, holding that Revenue failed to prove contravention of s.269SS by the Respondent-Assessee. The Tribunal emphasized that s.269SS is predicated on receipt of money in cash and non-cash modes permissible under Rule 6ABBA, and the Assessing Officer did not adduce any direct evidence of cash receipt in the immovable property sale. Reliance on generalized practices and circumstantial inferences without a DVO report or concrete material was held insufficient. Consequently, penalty under s.271D could not be sustained and the appeal was dismissed.
ITAT dismissed the appeal of Appellant-Revenue and upheld the CIT(A)'s deletion of penalty under s.271D, holding that Revenue failed to prove contravention of s.269SS by the Respondent-Assessee. The Tribunal emphasized that s.269SS is predicated on receipt of money in cash and non-cash modes permissible under Rule 6ABBA, and the Assessing Officer did not adduce any direct evidence of cash receipt in the immovable property sale. Reliance on generalized practices and circumstantial inferences without a DVO report or concrete material was held insufficient. Consequently, penalty under s.271D could not be sustained and the appeal was dismissed.
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