Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
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Penalty for alleged cash receipt cannot be imposed without demonstrative evidence establishing the actual cash transaction required for the cash-receipt restriction. Material showed a cash receipt only to a limited extent, while the balance was inferred conjecturally. Because the Revenue did not establish the factual basis for invoking section 269SS, deletion of the section 271D penalty was confirmed and its appeal dismissed.
Penalty for alleged cash receipt cannot be imposed without demonstrative evidence establishing the actual cash transaction required for the cash-receipt restriction. Material showed a cash receipt only to a limited extent, while the balance was inferred conjecturally. Because the Revenue did not establish the factual basis for invoking section 269SS, deletion of the section 271D penalty was confirmed and its appeal dismissed.
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