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...
Penalty u/s 271(1)(c) was imposed for denying deduction u/s 80DD for a disabled person with over 80% disability. The assessee, a retired individual, had submitted required medical documents but the deduction was denied. The ITAT held that merely making an incorrect claim which is not substantiated does not attract penalty u/s 271(1)(c), relying on the Supreme Court's decision in Reliance Petro-products Private Limited. The assessee had earned interest income but brought it to tax during assessment proceedings. Considering the facts, circumstances, and assessee's explanation, the ITAT set aside the penalty order u/s 271(1)(c) and allowed the appeal, holding that the lower authorities erroneously treated the penalty as automatic without considering Section 273.
Penalty u/s 271(1)(c) was imposed for denying deduction u/s 80DD for a disabled person with over 80% disability. The assessee, a retired individual, had submitted required medical documents but the deduction was denied. The ITAT held that merely making an incorrect claim which is not substantiated does not attract penalty u/s 271(1)(c), relying on the Supreme Court's decision in Reliance Petro-products Private Limited. The assessee had earned interest income but brought it to tax during assessment proceedings. Considering the facts, circumstances, and assessee's explanation, the ITAT set aside the penalty order u/s 271(1)(c) and allowed the appeal, holding that the lower authorities erroneously treated the penalty as automatic without considering Section 273.
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