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...
ITAT allowed the appeal in favour of the assessee and upheld the CIT(A)'s quashing of the penalty under s.271E. The Tribunal held the penalty order was time-barred under s.275(1)(c) since the limitation expired on 31.03.2023 but the penalty was imposed on 28.08.2023. Alternatively, the Tribunal found the transactions did not fall within the prohibitions of ss.269SS/269T and thus did not attract s.271E. The Tribunal also noted absence of requisite satisfaction recorded in the assessment order for initiating penalty proceedings, rendering any levy unsustainable. Consequently, the penalty was cancelled and the revenue's demand set aside.
ITAT allowed the appeal in favour of the assessee and upheld the CIT(A)'s quashing of the penalty under s.271E. The Tribunal held the penalty order was time-barred under s.275(1)(c) since the limitation expired on 31.03.2023 but the penalty was imposed on 28.08.2023. Alternatively, the Tribunal found the transactions did not fall within the prohibitions of ss.269SS/269T and thus did not attract s.271E. The Tribunal also noted absence of requisite satisfaction recorded in the assessment order for initiating penalty proceedings, rendering any levy unsustainable. Consequently, the penalty was cancelled and the revenue's demand set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
