Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
Penalty under section 271(1)(c) was contested where taxability of interest and commitment fees turned on interpretation of the India Germany DTAA and whether a representative office constituted a Permanent Establishment; AO taxed receipts at 40% but Tribunal treated them under Article 11 at 10%. The CIT(A) and Tribunal found the addition arose from the assessee's voluntary disclosures and a bona fide difference of opinion, invoking Reliance Petroproducts that an unsustainable claim alone does not constitute furnishing inaccurate particulars. Consequently no penalty was warranted and the appellant's appeal was allowed.
Penalty under section 271(1)(c) was contested where taxability of interest and commitment fees turned on interpretation of the India Germany DTAA and whether a representative office constituted a Permanent Establishment; AO taxed receipts at 40% but Tribunal treated them under Article 11 at 10%. The CIT(A) and Tribunal found the addition arose from the assessee's voluntary disclosures and a bona fide difference of opinion, invoking Reliance Petroproducts that an unsustainable claim alone does not constitute furnishing inaccurate particulars. Consequently no penalty was warranted and the appellant's appeal was allowed.
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