Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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The ITAT dismissed the assessee's appeal, upholding the levy of penalty under s.271(1)(c) insofar as it relates to additions confirmed by the Tribunal; the assessee failed to demonstrate any error in the quantum of additions as upheld by CIT(A) and ITAT. The rectification under s.154 by DCIT, which granted carry-forward of past losses inadvertently omitted, did not constitute a computational mistake affecting the confirmed additions and therefore does not mitigate penalty exposure. Because no infirmity was shown in the appellate order, no recalibration of the penalty relative to the s.154 reduction was warranted and the impugned assessment and penalty stand affirmed.
The ITAT dismissed the assessee's appeal, upholding the levy of penalty under s.271(1)(c) insofar as it relates to additions confirmed by the Tribunal; the assessee failed to demonstrate any error in the quantum of additions as upheld by CIT(A) and ITAT. The rectification under s.154 by DCIT, which granted carry-forward of past losses inadvertently omitted, did not constitute a computational mistake affecting the confirmed additions and therefore does not mitigate penalty exposure. Because no infirmity was shown in the appellate order, no recalibration of the penalty relative to the s.154 reduction was warranted and the impugned assessment and penalty stand affirmed.
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