Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
ITAT reversed penalty under s.271(1)(c) regarding transfer pricing adjustment on interest-free loans to associated enterprises. While TPO made upward adjustment at SBI PLR, later restricted to LIBOR+200bps, assessee had disclosed all relevant facts in returns. Bombay HC admitted appeal on substantial questions of law, indicating debatable nature of issue. Given that two reasonable interpretations were possible and necessary disclosures were made, penalty for furnishing inaccurate income particulars was deemed unjustified. The tribunal emphasized that when legal interpretations are genuinely disputable and pending higher court review, s.271(1)(c) penalties cannot be sustained. Revenue's grounds dismissed.
ITAT reversed penalty under s.271(1)(c) regarding transfer pricing adjustment on interest-free loans to associated enterprises. While TPO made upward adjustment at SBI PLR, later restricted to LIBOR+200bps, assessee had disclosed all relevant facts in returns. Bombay HC admitted appeal on substantial questions of law, indicating debatable nature of issue. Given that two reasonable interpretations were possible and necessary disclosures were made, penalty for furnishing inaccurate income particulars was deemed unjustified. The tribunal emphasized that when legal interpretations are genuinely disputable and pending higher court review, s.271(1)(c) penalties cannot be sustained. Revenue's grounds dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
