Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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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