Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
The article addresses penalty proceedings under section 271D for alleged contravention of section 269SS: tribunals have held that cash received as part of sale consideration expressly recorded in a registered sale deed may fall outside the prohibition on specified cash receipts, and penalty cannot stand where the Assessing Officer has not recorded satisfaction in assessment proceedings. It further notes limitation rulings applying the TOLA extension as making show-cause notices issued well after the extended reasonable period time-barred; on those grounds the impugned penalty was deleted and the assessee's appeal allowed.
The article addresses penalty proceedings under section 271D for alleged contravention of section 269SS: tribunals have held that cash received as part of sale consideration expressly recorded in a registered sale deed may fall outside the prohibition on specified cash receipts, and penalty cannot stand where the Assessing Officer has not recorded satisfaction in assessment proceedings. It further notes limitation rulings applying the TOLA extension as making show-cause notices issued well after the extended reasonable period time-barred; on those grounds the impugned penalty was deleted and the assessee's appeal allowed.
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