Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
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ITAT upheld penalty under section 270A for under-reporting in consequence of misreporting, holding that the assessee's deduction claim for a political donation was based on a non-genuine transaction exposed through investigation. The later withdrawal of the claim in response to notice under section 148 was not voluntary but a post-detection attempt to reduce consequences, so it did not cure the initial misrepresentation. The Tribunal also rejected the challenge to the penalty notice, finding that the specific statutory limb under section 270A(9)(a) had been clearly invoked and the assessee was aware of the precise allegation. The appeal was dismissed.
ITAT upheld penalty under section 270A for under-reporting in consequence of misreporting, holding that the assessee's deduction claim for a political donation was based on a non-genuine transaction exposed through investigation. The later withdrawal of the claim in response to notice under section 148 was not voluntary but a post-detection attempt to reduce consequences, so it did not cure the initial misrepresentation. The Tribunal also rejected the challenge to the penalty notice, finding that the specific statutory limb under section 270A(9)(a) had been clearly invoked and the assessee was aware of the precise allegation. The appeal was dismissed.
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