Lodha Builders Pvt Ltd Vs ACIT Income Tax - Sections 14A, 115JB, 269SS, 271D, 273B & 275(1)(c) Whether liabilities or debt which are discharged by way of journal entries are covered by the provisions of section 269SS or 269T - Whether involvement of cash transaction is sine qua non for imposing the penalty of section 269SS or 269T - Whether action for initiation of penalty is always anterior to the action of actual imposition of penalty - Whether penalties which are covered by the provisions of section 269SS and 269T are not dependent on the outcome of appellate proceedings - Whether limitation period in such cases should be reckoned from the date of the notice issued by the AO and not from the date of notice issued by the Additional CIT - Whether decision of High Court would supersede the decision of Special Bench and hence the same is to be followed as per judicial hierarchy - Whether expression "reasonable cause" as appearing in section 273B is of wider connotation than "sufficient cause" and hence the same should be construed liberally - Whether before applying provisions of section 269T or 269SS the genuineness of the transactions and recording of the same in the books of accounts would be given weightage - Whether completing empty formalities of payments and repayments via journal entries falls under the umbrella of "reasonable cause" as envisaged under section 273B of the Act and hence no penalty in such transactions. - Assessee's appeal allowed : MUMBAI ITAT |  | |
 | ||
Regards
Prarthana Jalan
__._,_.___
No comments:
Post a Comment