Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
The ITAT Mumbai upheld the levy of penalty u/s 271(1)(c) for bogus LTCG. Exemption u/s 10(38) denied as revised income declaration was not voluntary but in response to u/s 148 notice. Citing MAK Data case, voluntary disclosure doesn't prevent penal proceedings. Assessee failed to provide evidence for share transaction genuineness. Additional income declared only after u/s 148 notice, not voluntarily. No merit in argument that penalty cannot be imposed as returned and assessed income are same. Penalty upheld as bogus LTCG was claimed exempt initially. Assessee's appeal dismissed.
The ITAT Mumbai upheld the levy of penalty u/s 271(1)(c) for bogus LTCG. Exemption u/s 10(38) denied as revised income declaration was not voluntary but in response to u/s 148 notice. Citing MAK Data case, voluntary disclosure doesn't prevent penal proceedings. Assessee failed to provide evidence for share transaction genuineness. Additional income declared only after u/s 148 notice, not voluntarily. No merit in argument that penalty cannot be imposed as returned and assessed income are same. Penalty upheld as bogus LTCG was claimed exempt initially. Assessee's appeal dismissed.
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