Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Penalty u/s. 271(1)(c) - Referring to a precedent set by the Hon’ble Supreme Court in CIT vs. Suresh Chandra Mittal, the Tribunal emphasized that when an assessee voluntarily discloses additional income to resolve tax disputes, such disclosure should be considered bona fide. - The Tribunal observed that the vouchers for the purchases were self-made and subsequently treated as bogus by the AO. It concluded that this situation mirrored the circumstances in the Suresh Chandra Mittal case, where penalties were canceled due to the assessee's bona fide explanation. Consequently, the Tribunal deleted the penalties imposed by the AO.
Penalty u/s. 271(1)(c) - Referring to a precedent set by the Hon’ble Supreme Court in CIT vs. Suresh Chandra Mittal, the Tribunal emphasized that when an assessee voluntarily discloses additional income to resolve tax disputes, such disclosure should be considered bona fide. - The Tribunal observed that the vouchers for the purchases were self-made and subsequently treated as bogus by the AO. It concluded that this situation mirrored the circumstances in the Suresh Chandra Mittal case, where penalties were canceled due to the assessee's bona fide explanation. Consequently, the Tribunal deleted the penalties imposed by the AO.
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