Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The ITAT Mumbai ruled on penalty u/s 271(1)(c) for estimation of income on bogus purchases. The tribunal held that penalty cannot be levied on additions made on an estimate basis unless clear proof of concealment or furnishing inaccurate particulars is shown. As the addition was based on 6% of unproved purchases, considered an estimate, the penalty was deemed unjustified. Therefore, the penalty u/s 271(1)(c) was deleted, allowing the assessee's appeal.
The ITAT Mumbai ruled on penalty u/s 271(1)(c) for estimation of income on bogus purchases. The tribunal held that penalty cannot be levied on additions made on an estimate basis unless clear proof of concealment or furnishing inaccurate particulars is shown. As the addition was based on 6% of unproved purchases, considered an estimate, the penalty was deemed unjustified. Therefore, the penalty u/s 271(1)(c) was deleted, allowing the assessee's appeal.
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