Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Penalty u/s 271(1)(c) - bogus claim u/s 80C - The Tribunal found that there was a discrepancy in the application of penalties by the lower authorities. - While the Assessing Officer concluded it as a case of furnishing inaccurate particulars of income, the subsequent discussion by the National Faceless Appeal Centre deemed it as concealment of taxable income. - Citing a relevant high court decision, the Tribunal deemed this deviation unsustainable in law. - Consequently, the penalty was deemed inappropriate and was deleted.
Penalty u/s 271(1)(c) - bogus claim u/s 80C - The Tribunal found that there was a discrepancy in the application of penalties by the lower authorities. - While the Assessing Officer concluded it as a case of furnishing inaccurate particulars of income, the subsequent discussion by the National Faceless Appeal Centre deemed it as concealment of taxable income. - Citing a relevant high court decision, the Tribunal deemed this deviation unsustainable in law. - Consequently, the penalty was deemed inappropriate and was deleted.
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