Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Penalty u/s 271(1)(c) - non disclosure of capital gain on sale of land in the income tax return - Sale consideration by applying the provisions of section 50C (i.e deeming fiction) - It is an admitted fact that there cannot be any penalty on the profit calculated for the assessee based on deeming section/fiction. - the revenue is not expected to derive any benefit out of the ignorance of the assessee. - there was no deliberate act on part of the assessee to conceal/furnish inaccurate particulars of income - No penalty - AT
Penalty u/s 271(1)(c) - non disclosure of capital gain on sale of land in the income tax return - Sale consideration by applying the provisions of section 50C (i.e deeming fiction) - It is an admitted fact that there cannot be any penalty on the profit calculated for the assessee based on deeming section/fiction. - the revenue is not expected to derive any benefit out of the ignorance of the assessee. - there was no deliberate act on part of the assessee to conceal/furnish inaccurate particulars of income - No penalty - AT
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