Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
The assessee, a foreign-based company, initially failed to comply with the notice u/s 92D(3) within the statutory period of 60 days, responding on 25.03.2019 after a delay of 38 days. However, the Income Tax Appellate Tribunal (ITAT) considered the delay as minuscule and the reasons for non-compliance as bona fide and unintentional, given the peculiar circumstances of the assessee being a foreign entity and in the process of appointing a new authorized representative. The ITAT held that the penalty u/s 271G for non-compliance should be deleted, accepting the assessee's reasons for the inadvertent delay as reasonable. Consequently, the assessee's appeal against the penalty was allowed.
The assessee, a foreign-based company, initially failed to comply with the notice u/s 92D(3) within the statutory period of 60 days, responding on 25.03.2019 after a delay of 38 days. However, the Income Tax Appellate Tribunal (ITAT) considered the delay as minuscule and the reasons for non-compliance as bona fide and unintentional, given the peculiar circumstances of the assessee being a foreign entity and in the process of appointing a new authorized representative. The ITAT held that the penalty u/s 271G for non-compliance should be deleted, accepting the assessee's reasons for the inadvertent delay as reasonable. Consequently, the assessee's appeal against the penalty was allowed.
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