Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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Penalty u/s 270A - misreporting of the income - disallowances of 40A(3) on account of interest income in the other sources and has also disallowed the claim of the assessee u/s 32 disputing the period use of the asset of the assessee - The Tribunal emphasized the distinction between assessment and penalty proceedings and noted that the mere addition in assessment did not automatically imply concealment. The ITAT also highlighted the appellant's compliance with depositing the demand within the stipulated time frame, albeit the procedural lapse in filing Form No. 68. Ultimately, the Tribunal ruled in favor of the appellant, directing the deletion of the penalty levied under section 270A of the Act.
Penalty u/s 270A - misreporting of the income - disallowances of 40A(3) on account of interest income in the other sources and has also disallowed the claim of the assessee u/s 32 disputing the period use of the asset of the assessee - The Tribunal emphasized the distinction between assessment and penalty proceedings and noted that the mere addition in assessment did not automatically imply concealment. The ITAT also highlighted the appellant's compliance with depositing the demand within the stipulated time frame, albeit the procedural lapse in filing Form No. 68. Ultimately, the Tribunal ruled in favor of the appellant, directing the deletion of the penalty levied under section 270A of the Act.
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