Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Penalty under section 271C was held unsustainable where the order was passed beyond the six-month limit prescribed by section 275(1)(c), as fiscal limitation provisions must be strictly applied and penalty cannot be imposed after expiry of that period. The tribunal also noted that the alleged default arose from a disallowance treated as interest-related expenditure, yet the reference for penalty was made after an inordinate 18-month delay. That delay was found to defeat the object of section 275(1)(c), and the penalty order, as well as the appellate affirmation, was set aside and the penalty deleted.
Penalty under section 271C was held unsustainable where the order was passed beyond the six-month limit prescribed by section 275(1)(c), as fiscal limitation provisions must be strictly applied and penalty cannot be imposed after expiry of that period. The tribunal also noted that the alleged default arose from a disallowance treated as interest-related expenditure, yet the reference for penalty was made after an inordinate 18-month delay. That delay was found to defeat the object of section 275(1)(c), and the penalty order, as well as the appellate affirmation, was set aside and the penalty deleted.
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