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...
ITAT deleted penalty for under-reporting of income under section 270A because the income had already been disclosed and was reflected through salary records, TDS and Form 26AS. The Tribunal noted that the addition arose from non-consideration of available material, while the appellate relief aligned the assessed income with the returned income. Once the quantum addition was deleted, the statutory condition for under-reporting ceased to exist, and there was no basis to infer concealment or misreporting. The consequential penalty therefore could not be sustained and the assessee's appeal was allowed.
ITAT deleted penalty for under-reporting of income under section 270A because the income had already been disclosed and was reflected through salary records, TDS and Form 26AS. The Tribunal noted that the addition arose from non-consideration of available material, while the appellate relief aligned the assessed income with the returned income. Once the quantum addition was deleted, the statutory condition for under-reporting ceased to exist, and there was no basis to infer concealment or misreporting. The consequential penalty therefore could not be sustained and the assessee's appeal was allowed.
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