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Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
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Levy of penalty u/s. 271(1)(c) - The appellant contended that the addition made by the Assessing Officer was based solely on estimations, making it ineligible for penalty imposition. The ITAT upheld this argument, citing legal precedents to support its decision. Additionally, the court noted the defective nature of the penalty notice issued by the Assessing Officer, further bolstering the appellant's case. - Consequently, the Tribunal set aside the impugned order and allowed the appellant's appeal, directing the deletion of the penalty.
Levy of penalty u/s. 271(1)(c) - The appellant contended that the addition made by the Assessing Officer was based solely on estimations, making it ineligible for penalty imposition. The ITAT upheld this argument, citing legal precedents to support its decision. Additionally, the court noted the defective nature of the penalty notice issued by the Assessing Officer, further bolstering the appellant's case. - Consequently, the Tribunal set aside the impugned order and allowed the appellant's appeal, directing the deletion of the penalty.
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