Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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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