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...
Penalty u/s 271(1)(c) was imposed on the assessee for not filing the return of income (ROI), despite having a bona fide belief that the income was non-taxable and tax deducted at source (TDS) was deducted on the income. The assessee, a non-profit welfare fund, filed the return and paid the tax in full after receiving a notice u/s 148, before receiving the recorded reasons. The Assessing Officer accepted the return and tax paid, with no findings of concealment of income. Relying on relevant judicial precedents, the Tribunal held that the levy of penalty was unjustified and quashed the penalty u/s 271(1)(c), allowing the assessee's appeal.
Penalty u/s 271(1)(c) was imposed on the assessee for not filing the return of income (ROI), despite having a bona fide belief that the income was non-taxable and tax deducted at source (TDS) was deducted on the income. The assessee, a non-profit welfare fund, filed the return and paid the tax in full after receiving a notice u/s 148, before receiving the recorded reasons. The Assessing Officer accepted the return and tax paid, with no findings of concealment of income. Relying on relevant judicial precedents, the Tribunal held that the levy of penalty was unjustified and quashed the penalty u/s 271(1)(c), allowing the assessee's appeal.
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