Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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Penalty for furnishing inaccurate particulars was upheld where commission expenditure was found non-genuine, as third-party verification showed the alleged intermediaries had not rendered services and the assessee failed to substantiate the claim. Where penalty had been computed on additions not finally sustained in appeal, it was treated as a mistake apparent from the record and was directed to be recomputed only on the surviving addition. Penalty under section 41(1) for waiver of interest liability was deleted for one year because the assessee's explanation based on a bona fide one-time settlement with banks was accepted, and penalty was not automatic merely because the addition survived.
Penalty for furnishing inaccurate particulars was upheld where commission expenditure was found non-genuine, as third-party verification showed the alleged intermediaries had not rendered services and the assessee failed to substantiate the claim. Where penalty had been computed on additions not finally sustained in appeal, it was treated as a mistake apparent from the record and was directed to be recomputed only on the surviving addition. Penalty under section 41(1) for waiver of interest liability was deleted for one year because the assessee's explanation based on a bona fide one-time settlement with banks was accepted, and penalty was not automatic merely because the addition survived.
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