Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
ITAT allowed the appeals and directed deletion of penalties under ss. 271(1)(b) and 272A(1)(d), holding that non-compliance with notice under s. 142(1) was not deliberate but pursuant to legal advice and an application under s. 245D(1) to the ITSC, thereby constituting reasonable cause; s. 273B relief applied. The Tribunal further observed that subsequent quashing of assessments under ss. 153A/153C by the HC and remittance of the s. 245D(1) applications to the ITSC removed any basis for penalty. Consequentially, penalties confirmed by the CIT(A) were unjustified and deleted for all appellants; appeals allowed.
ITAT allowed the appeals and directed deletion of penalties under ss. 271(1)(b) and 272A(1)(d), holding that non-compliance with notice under s. 142(1) was not deliberate but pursuant to legal advice and an application under s. 245D(1) to the ITSC, thereby constituting reasonable cause; s. 273B relief applied. The Tribunal further observed that subsequent quashing of assessments under ss. 153A/153C by the HC and remittance of the s. 245D(1) applications to the ITSC removed any basis for penalty. Consequentially, penalties confirmed by the CIT(A) were unjustified and deleted for all appellants; appeals allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
