Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
Page of 4809
Press 'Enter' after typing page number.
2061 to 2080 of 96177 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT held that penalty under section 270A could not be sustained where the assessee had made full disclosure of a trading loss and the AO's action amounted only to a taxonomic recharacterisation from non-speculative business loss to speculation loss. No additional tax was levied and there was no foundational under-reported income or culpable conduct as required for imposition of the statutory penalty. The Tribunal agreed with the appellate authority that the issue was one of legal characterisation of an admitted claim, not suppression or falsity, and therefore the rigours of section 270A were inapplicable. Penalty deleted and decision affirmed in favour of the assessee.
ITAT held that penalty under section 270A could not be sustained where the assessee had made full disclosure of a trading loss and the AO's action amounted only to a taxonomic recharacterisation from non-speculative business loss to speculation loss. No additional tax was levied and there was no foundational under-reported income or culpable conduct as required for imposition of the statutory penalty. The Tribunal agreed with the appellate authority that the issue was one of legal characterisation of an admitted claim, not suppression or falsity, and therefore the rigours of section 270A were inapplicable. Penalty deleted and decision affirmed in favour of the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
