Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The ITAT Mumbai, in a case involving penalty u/s 271(1)(c) for estimation of income on bogus purchases, held that when additions are based on estimation, no penalty can be imposed. The CIT(A) had limited the disallowance to 17.5%, which was further reduced to 8% by the Tribunal. The Tribunal found that adhoc disallowance of purchases does not amount to furnishing inaccurate particulars of income. Citing M/s Nikunj Eximp Enterprises, the Tribunal directed the AO to delete the penalty, overturning the CIT(A)'s decision. The appeal was allowed in favor of the assessee based on facts, circumstances, and legal precedents.
The ITAT Mumbai, in a case involving penalty u/s 271(1)(c) for estimation of income on bogus purchases, held that when additions are based on estimation, no penalty can be imposed. The CIT(A) had limited the disallowance to 17.5%, which was further reduced to 8% by the Tribunal. The Tribunal found that adhoc disallowance of purchases does not amount to furnishing inaccurate particulars of income. Citing M/s Nikunj Eximp Enterprises, the Tribunal directed the AO to delete the penalty, overturning the CIT(A)'s decision. The appeal was allowed in favor of the assessee based on facts, circumstances, and legal precedents.
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