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Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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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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