Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
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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