Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
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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