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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Penalty u/s. 271(1)(c) - The Revenue argued that the assessee's actions constituted furnishing inaccurate particulars of income or concealing income. However, the High Court disagreed, ruling that the claim for deductions was bona fide and directly linked to the business profit. They emphasized that the mere rejection of a claim by the Assessing Officer does not automatically result in the imposition of penalties under Section 271(1)(c). Therefore, the High Court concluded that no substantial questions of law arose from the case and dismissed the appeal of the Revenue.
Penalty u/s. 271(1)(c) - The Revenue argued that the assessee's actions constituted furnishing inaccurate particulars of income or concealing income. However, the High Court disagreed, ruling that the claim for deductions was bona fide and directly linked to the business profit. They emphasized that the mere rejection of a claim by the Assessing Officer does not automatically result in the imposition of penalties under Section 271(1)(c). Therefore, the High Court concluded that no substantial questions of law arose from the case and dismissed the appeal of the Revenue.
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