Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Penalty under s.271D for alleged contravention of s.269SS was examined on whether the assessee had "reasonable cause" under s.273B for receiving sale consideration in cash. The assessee received cash advance and balance consideration pursuant to a sale agreement executed before the amendment to s.269SS effective 01.06.2015, completed the registered conveyance in the presence of witnesses, and disclosed the full consideration with due taxes paid. Since the cash receipts were in terms of a pre-amendment contractual arrangement, the statutory "reasonable cause" protection applied, rendering the penalty unsustainable; the penalty was deleted and the appeal was allowed. - ITAT
Penalty under s.271D for alleged contravention of s.269SS was examined on whether the assessee had "reasonable cause" under s.273B for receiving sale consideration in cash. The assessee received cash advance and balance consideration pursuant to a sale agreement executed before the amendment to s.269SS effective 01.06.2015, completed the registered conveyance in the presence of witnesses, and disclosed the full consideration with due taxes paid. Since the cash receipts were in terms of a pre-amendment contractual arrangement, the statutory "reasonable cause" protection applied, rendering the penalty unsustainable; the penalty was deleted and the appeal was allowed. - ITAT
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