Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
Levy of Penalty u/s. 271(1)(c) - The ITAT ruled that since there was no variation between the returned and assessed income, there was no concealment of income by the assessee. - Referring to legal precedents, the ITAT highlighted that the penalty under Section 271(1)(c) can only be levied if there is concealment or furnishing of inaccurate particulars, which must be determined with reference to the returned income. - As there was no discrepancy between the returned and assessed income, the tribunal instructed the A.O. to delete the penalty imposed under Section 271(1)(c).
Levy of Penalty u/s. 271(1)(c) - The ITAT ruled that since there was no variation between the returned and assessed income, there was no concealment of income by the assessee. - Referring to legal precedents, the ITAT highlighted that the penalty under Section 271(1)(c) can only be levied if there is concealment or furnishing of inaccurate particulars, which must be determined with reference to the returned income. - As there was no discrepancy between the returned and assessed income, the tribunal instructed the A.O. to delete the penalty imposed under Section 271(1)(c).
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