Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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The ITAT upheld the deletion of the penalty under section 271(1)(c) where the assessee voluntarily disclosed undisclosed income in the return filed under section 153A, which was accepted by the AO. The Tribunal found no incriminating material during the search regarding the disclosed income, which related to outstanding liabilities reflected in the books. Since the surrendered income was admitted and taxed without concealment or furnishing inaccurate particulars, the imposition of penalty was unwarranted. The CIT(A)'s acceptance of the income return reflecting a substantial loss further supported the absence of tax evasion. Consequently, the penalty was quashed, and the assessee's appeal was allowed.
The ITAT upheld the deletion of the penalty under section 271(1)(c) where the assessee voluntarily disclosed undisclosed income in the return filed under section 153A, which was accepted by the AO. The Tribunal found no incriminating material during the search regarding the disclosed income, which related to outstanding liabilities reflected in the books. Since the surrendered income was admitted and taxed without concealment or furnishing inaccurate particulars, the imposition of penalty was unwarranted. The CIT(A)'s acceptance of the income return reflecting a substantial loss further supported the absence of tax evasion. Consequently, the penalty was quashed, and the assessee's appeal was allowed.
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