International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
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Penalty under section 271(1)(c) could not be sustained where the disallowance arose from a debatable claim for proportionate amortisation of lease premium and the jurisdictional High Court had already admitted a substantial question of law in the assessee's own case. The Tribunal held that the claim was bona fide and, following Reliance Petroproducts, mere making of an unsustainable claim did not amount to furnishing inaccurate particulars absent any finding that the particulars were false or erroneous. On that basis, the penalty for both assessment years was quashed.
Penalty under section 271(1)(c) could not be sustained where the disallowance arose from a debatable claim for proportionate amortisation of lease premium and the jurisdictional High Court had already admitted a substantial question of law in the assessee's own case. The Tribunal held that the claim was bona fide and, following Reliance Petroproducts, mere making of an unsustainable claim did not amount to furnishing inaccurate particulars absent any finding that the particulars were false or erroneous. On that basis, the penalty for both assessment years was quashed.
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