Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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ITAT held that penalty u/s 270A is unsustainable where deduction claim was made transparently based on existing legal interpretation prior to retrospective amendment. The assessee voluntarily surrendered the claim upon becoming aware of amendment and fully disclosed facts during assessment proceedings. No allegation of concealment or suppression existed. Relying on judicial precedent, the tribunal concluded that bona fide interpretation of law, even if subsequently found incorrect, does not attract penalty. The assessee's appeal was allowed, restricting penalty imposition.
ITAT held that penalty u/s 270A is unsustainable where deduction claim was made transparently based on existing legal interpretation prior to retrospective amendment. The assessee voluntarily surrendered the claim upon becoming aware of amendment and fully disclosed facts during assessment proceedings. No allegation of concealment or suppression existed. Relying on judicial precedent, the tribunal concluded that bona fide interpretation of law, even if subsequently found incorrect, does not attract penalty. The assessee's appeal was allowed, restricting penalty imposition.
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