Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Penalty u/s 271(1)(c) - addition sustained by denying the exemption u/s 47(xiv) to the extent of self-generated Goodwill - all the details necessary for assessment were very much available in the return of income itself as well as the entire facts of proprietory concern getting converted into public limited company - no malafide on the part of the assessee in making the claim of exemption - no penalty
Penalty u/s 271(1)(c) - addition sustained by denying the exemption u/s 47(xiv) to the extent of self-generated Goodwill - all the details necessary for assessment were very much available in the return of income itself as well as the entire facts of proprietory concern getting converted into public limited company - no malafide on the part of the assessee in making the claim of exemption - no penalty
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