Prospective valuation amendment limits reassessment: unamended fair market value reference could not justify reopening based on a registered valuer's ...
Exemption for examination-related services rejected where recipients were commercial entities; suppression sustained extended limitation and penalties...
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Penalty u/s 271(1)(c) - disallowance of professional fees for non-deduction of TDS - Merely not filing appeal on the contesting issues does not tantamount to concealment of income and furnishing inaccurate particulars of income. These two elements along with Explanation 1 of Section 271(1)(c) are not present in assessee’s case for imposing penalty or initiating penalty proceedings. As related to payment made to control risk, the same also does not impugned to FTS as per the provisions of Article 12(4) of India Singapore DTAA as the same does not result in making available technical knowhow to the recipient. - No penalty - AT
Penalty u/s 271(1)(c) - disallowance of professional fees for non-deduction of TDS - Merely not filing appeal on the contesting issues does not tantamount to concealment of income and furnishing inaccurate particulars of income. These two elements along with Explanation 1 of Section 271(1)(c) are not present in assessee’s case for imposing penalty or initiating penalty proceedings. As related to payment made to control risk, the same also does not impugned to FTS as per the provisions of Article 12(4) of India Singapore DTAA as the same does not result in making available technical knowhow to the recipient. - No penalty - AT
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