Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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Penalty under section 271(1)(c) could not be sustained where the assessee had disclosed all particulars in the return and the claim was only disallowed as a matter of law. Applying CIT v. Reliance Petro Products Ltd., the ITAT held that concealment of income or furnishing of inaccurate particulars is required for penalty, and a mere unsustainable claim for document and stamp charges related to increase in authorised share capital does not meet that test. The penalty was deleted and the assessee's appeal was allowed.
Penalty under section 271(1)(c) could not be sustained where the assessee had disclosed all particulars in the return and the claim was only disallowed as a matter of law. Applying CIT v. Reliance Petro Products Ltd., the ITAT held that concealment of income or furnishing of inaccurate particulars is required for penalty, and a mere unsustainable claim for document and stamp charges related to increase in authorised share capital does not meet that test. The penalty was deleted and the assessee's appeal was allowed.
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