https://www.taxtmi.com/caselaws?id=783876 In penalty-linked additions under ss. 271D/271E, the Department inferred cash loan and cash repayment, but in the absence of corroborative material establishing actual cash transmission and return, the inference was held unsustainable; the corresponding addition was deleted. On s. 153D approval, though the approval note was brief, the record showed a short draft assessment was transmitted and approval granted after perusal, and with additions already deleted on merits, the challenge was rejected without adjudication on merits. For s. 80-IC, head-office expenses such as professional charges, gratuity, charity/donations and IPO expenses were not shown to be relatable to the eligible unit; the apportionment disallowance was deleted. As the quantum additions were deleted, penalty under s. 271AAA was held to lack foundation and was deleted. en-us Wed, 18 Jun 2025 00:00:00 +0530 Wed, 24 Dec 2025 07:51:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783876 In penalty-linked additions under ss. 271D/271E, the Department inferred cash loan and cash repayment, but in the absence of corroborative material establishing actual cash transmission and return, the inference was held unsustainable; the corresponding addition was deleted. On s. 153D approval, though the approval note was brief, the record showed a short draft assessment was transmitted and approval granted after perusal, and with additions already deleted on merits, the challenge was rejected without adjudication on merits. For s. 80-IC, head-office expenses such as professional charges, gratuity, charity/donations and IPO expenses were not shown to be relatable to the eligible unit; the apportionment disallowance was deleted. As the quantum additions were deleted, penalty under s. 271AAA was held to lack foundation and was deleted. Case-Laws Income Tax Wed, 18 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783876