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...
Once the jurisdictional High Court had admitted the assessee's quantum appeal on substantial questions of law concerning the transfer pricing addition, the underlying addition had not attained finality and remained debatable. In that situation, the Tribunal applied the principle that a debatable claim does not by itself establish concealment of income or furnishing of inaccurate particulars. Penalty under section 271(1)(c) was therefore held not leviable, and the deletion of penalty was upheld.
Once the jurisdictional High Court had admitted the assessee's quantum appeal on substantial questions of law concerning the transfer pricing addition, the underlying addition had not attained finality and remained debatable. In that situation, the Tribunal applied the principle that a debatable claim does not by itself establish concealment of income or furnishing of inaccurate particulars. Penalty under section 271(1)(c) was therefore held not leviable, and the deletion of penalty was upheld.
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