Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Penalty for under-reporting or misreporting of income under section 270A requires clear identification and communication of the applicable circumstance of under-reporting and, where relevant, the act constituting misreporting. Failure to specify these statutory grounds in the assessment order, notice or penalty order denies the taxpayer an effective opportunity to respond and breaches natural justice. Where the charge finally used to impose penalty differs from the charge initially invoked, the penalty proceedings are invalid. The section 270A penalty was therefore quashed as bad in law.
Penalty for under-reporting or misreporting of income under section 270A requires clear identification and communication of the applicable circumstance of under-reporting and, where relevant, the act constituting misreporting. Failure to specify these statutory grounds in the assessment order, notice or penalty order denies the taxpayer an effective opportunity to respond and breaches natural justice. Where the charge finally used to impose penalty differs from the charge initially invoked, the penalty proceedings are invalid. The section 270A penalty was therefore quashed as bad in law.
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