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) - deduction u/s. 80GGC denied - second round of appeal - the Tribunal ruled in favor of the assessee, holding that the claim for deduction was made in good faith. They emphasized that the claim was based on the opinion of the auditor and was supported by genuine belief. Despite the deduction being ultimately disallowed, the authorities found that there was no intention to provide inaccurate particulars of income. Therefore, the penalty under section 271(1)(c) was deemed unjustified and was deleted.
Penalty u/s. 271(1)(c) - deduction u/s. 80GGC denied - second round of appeal - the Tribunal ruled in favor of the assessee, holding that the claim for deduction was made in good faith. They emphasized that the claim was based on the opinion of the auditor and was supported by genuine belief. Despite the deduction being ultimately disallowed, the authorities found that there was no intention to provide inaccurate particulars of income. Therefore, the penalty under section 271(1)(c) was deemed unjustified and was deleted.
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