Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Penalty under section 270A was deleted because the assessee had voluntarily disclosed additional income in the return filed under section 153C and paid tax and interest before assessment proceedings began. The Tribunal treated the earlier omission in the section 139 return as an inadvertent, bona fide mistake and relied on the principle that penalty is not automatic merely because higher income is later offered and accepted. On those facts, the disclosure and payment were held sufficient to negate penalty.
Penalty under section 270A was deleted because the assessee had voluntarily disclosed additional income in the return filed under section 153C and paid tax and interest before assessment proceedings began. The Tribunal treated the earlier omission in the section 139 return as an inadvertent, bona fide mistake and relied on the principle that penalty is not automatic merely because higher income is later offered and accepted. On those facts, the disclosure and payment were held sufficient to negate penalty.
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