Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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The ITAT deleted the penalty imposed u/s 271(1)(c) for determination of the correct head of income. The assessee had treated compensation received on termination of agency rights as business income. The ITAT relied on the jurisdictional High Court's decisions in Bennett Coleman & Co Ltd and CIT vs Procter & Gamble Hygiene and Healthcare Ltd, which held that no penalty could be levied for a mere change of head of income by the Assessing Officer, unless concealment of income or furnishing of inaccurate particulars was established. Consequently, the penalty was deleted regarding the compensation received on termination of the agreement. Additionally, penalties on three other additions were also deleted as those issues were restored to the Assessing Officer's file.
The ITAT deleted the penalty imposed u/s 271(1)(c) for determination of the correct head of income. The assessee had treated compensation received on termination of agency rights as business income. The ITAT relied on the jurisdictional High Court's decisions in Bennett Coleman & Co Ltd and CIT vs Procter & Gamble Hygiene and Healthcare Ltd, which held that no penalty could be levied for a mere change of head of income by the Assessing Officer, unless concealment of income or furnishing of inaccurate particulars was established. Consequently, the penalty was deleted regarding the compensation received on termination of the agreement. Additionally, penalties on three other additions were also deleted as those issues were restored to the Assessing Officer's file.
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