Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Penalty under section 270A was deleted where the assessee claimed deduction for Health and Education Cess on a bona fide legal view supported by existing High Court precedents, fully disclosed the claim in the return, and voluntarily withdrew the claim during assessment after a retrospective statutory explanation was introduced. Applying the principle that a claim made on a debatable legal interpretation with full disclosure and without concealment does not attract penalty, the case falls within the non-penalising scope of the relevant proviso, leading to deletion of the penalty.
Penalty under section 270A was deleted where the assessee claimed deduction for Health and Education Cess on a bona fide legal view supported by existing High Court precedents, fully disclosed the claim in the return, and voluntarily withdrew the claim during assessment after a retrospective statutory explanation was introduced. Applying the principle that a claim made on a debatable legal interpretation with full disclosure and without concealment does not attract penalty, the case falls within the non-penalising scope of the relevant proviso, leading to deletion of the penalty.
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