Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Penalty u/s 271(1)(c) was imposed for excess deduction claimed u/s 10B. The assessee furnished all relevant facts for computing total income, and provided detailed explanations regarding the claim u/s 10B, including the number of manufacturing divisions, bifurcation of expenditure, and availability of carried forward losses. The explanation was not found false, and the onus to prove falsity lies on the revenue. The claim was an allowable deduction, though the quantum was reworked by the Assessing Officer using different arithmetic. All details and justifications were provided in the return itself. The amount of tax sought to be evaded under explanation 1 to section 271(1)(c) was indeterminable for imposing penalty. The assessee's decision to not appeal the reduction of claim does not imply lack of bona fides. The CIT(A) rightly deleted the penalty, and no interference is warranted.
Penalty u/s 271(1)(c) was imposed for excess deduction claimed u/s 10B. The assessee furnished all relevant facts for computing total income, and provided detailed explanations regarding the claim u/s 10B, including the number of manufacturing divisions, bifurcation of expenditure, and availability of carried forward losses. The explanation was not found false, and the onus to prove falsity lies on the revenue. The claim was an allowable deduction, though the quantum was reworked by the Assessing Officer using different arithmetic. All details and justifications were provided in the return itself. The amount of tax sought to be evaded under explanation 1 to section 271(1)(c) was indeterminable for imposing penalty. The assessee's decision to not appeal the reduction of claim does not imply lack of bona fides. The CIT(A) rightly deleted the penalty, and no interference is warranted.
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