Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Misreporting of income under section 270A is not established merely because a donation deduction claimed under section 80GGC was disclosed in the return and later disallowed or withdrawn in a reassessment return. Misreporting requires material indicating deliberate furnishing of inaccurate particulars, false evidence, suppression, or misrepresentation. Where the taxpayer fulfils the substantive conditions for immunity under section 270AA(1), penalty protection applies. On these principles, the penalty imposed for misreporting was deleted and the appeal was allowed.
Misreporting of income under section 270A is not established merely because a donation deduction claimed under section 80GGC was disclosed in the return and later disallowed or withdrawn in a reassessment return. Misreporting requires material indicating deliberate furnishing of inaccurate particulars, false evidence, suppression, or misrepresentation. Where the taxpayer fulfils the substantive conditions for immunity under section 270AA(1), penalty protection applies. On these principles, the penalty imposed for misreporting was deleted and the appeal was allowed.
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