Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
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Penalty under s. 271AAB(1A)(b) was held unsustainable where the search did not unearth any incriminating material evidencing "undisclosed income" and the only basis was a statement under s. 132(4) offering additional income that was later retracted and was not reflected in the return for the relevant year. Since discovery of undisclosed income during or as a result of the search is a sine qua non for invoking s. 271AAB(1A)(b), a mere admission without corroborative seized material could not support penalty. Accordingly, deletion of the penalty was upheld and the revenue's appeal was dismissed. - ITAT
Penalty under s. 271AAB(1A)(b) was held unsustainable where the search did not unearth any incriminating material evidencing "undisclosed income" and the only basis was a statement under s. 132(4) offering additional income that was later retracted and was not reflected in the return for the relevant year. Since discovery of undisclosed income during or as a result of the search is a sine qua non for invoking s. 271AAB(1A)(b), a mere admission without corroborative seized material could not support penalty. Accordingly, deletion of the penalty was upheld and the revenue's appeal was dismissed. - ITAT
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