Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Penalty under section 271(1)(c) was held unsustainable where the disallowance arose from a deduction claim under section 80IB(10) on which courts had taken divergent views. The Tribunal treated the issue as debatable, noted that the controversy was pending before the Supreme Court, and applied Reliance Petroproducts to hold that a merely unsustainable claim does not amount to concealment or furnishing inaccurate particulars. On that basis, the statutory conditions for penalty were not met and the penalty was deleted.
Penalty under section 271(1)(c) was held unsustainable where the disallowance arose from a deduction claim under section 80IB(10) on which courts had taken divergent views. The Tribunal treated the issue as debatable, noted that the controversy was pending before the Supreme Court, and applied Reliance Petroproducts to hold that a merely unsustainable claim does not amount to concealment or furnishing inaccurate particulars. On that basis, the statutory conditions for penalty were not met and the penalty was deleted.
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