Appeal allows set-aside of transfer pricing adjustment imputing notional interest on integrated intercompany receivables after net margin exceeded com...
ITAT allowed the appeal and set aside the penalty under s. 271(1)(c), holding that the assessee had substantiated the claimed deduction for transfer expense and cost of improvement with vouchers and evidence of commission payment, while the AO failed to make enquiries or produce any material to rebut those particulars. In the absence of any evidence demonstrating that the particulars of income or expenses were inaccurate or that the assessee furnished false particulars, imposition of penalty was unjustified. Consequently, penalty proceedings were quashed and the assessment stands without the levy of s. 271(1)(c) penalty.
ITAT allowed the appeal and set aside the penalty under s. 271(1)(c), holding that the assessee had substantiated the claimed deduction for transfer expense and cost of improvement with vouchers and evidence of commission payment, while the AO failed to make enquiries or produce any material to rebut those particulars. In the absence of any evidence demonstrating that the particulars of income or expenses were inaccurate or that the assessee furnished false particulars, imposition of penalty was unjustified. Consequently, penalty proceedings were quashed and the assessment stands without the levy of s. 271(1)(c) penalty.
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