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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ITAT upheld CIT(A)'s order, rejecting revenue's penalty claim under section 270A against a charitable trust. The tribunal found no conditions met for penalty imposition, noting the assessee voluntarily filed a revised computation with corrected revenue expenditure. The tribunal determined the excess expenditure claim was within the statutory 15% limit under section 11(1)(a), and the discrepancy did not constitute a deliberate attempt to under-report income. Consequently, the penalty was deleted, and the decision was rendered in favor of the assessee.
ITAT upheld CIT(A)'s order, rejecting revenue's penalty claim under section 270A against a charitable trust. The tribunal found no conditions met for penalty imposition, noting the assessee voluntarily filed a revised computation with corrected revenue expenditure. The tribunal determined the excess expenditure claim was within the statutory 15% limit under section 11(1)(a), and the discrepancy did not constitute a deliberate attempt to under-report income. Consequently, the penalty was deleted, and the decision was rendered in favor of the assessee.
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