Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
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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