SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
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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