Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Penalty for non-disclosure of foreign assets was not sustained where the assessee disclosed the assets and foreign income in the return filed after search, and that return operated as the substituted return in place of the original return. Because the Revenue accepted the disclosure, made no addition in the assessment framed on the later return, and produced no material showing deliberate tax evasion, the earlier omission from the original return was treated as a bona fide technical lapse. On those facts, deletion of penalty under the Black Money Act was upheld.
Penalty for non-disclosure of foreign assets was not sustained where the assessee disclosed the assets and foreign income in the return filed after search, and that return operated as the substituted return in place of the original return. Because the Revenue accepted the disclosure, made no addition in the assessment framed on the later return, and produced no material showing deliberate tax evasion, the earlier omission from the original return was treated as a bona fide technical lapse. On those facts, deletion of penalty under the Black Money Act was upheld.
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