Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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