Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Penalty for failure to obtain an audit report was deleted because the assessee had consistently treated sale of shops as giving rise to capital gains, and the characterisation of the activity as business or investment was a debatable issue. The Tribunal found that the transactions were identical to those in the preceding year, when penalty had already been cancelled, and there was no distinguishing feature to justify a different view. On these facts, the assessee's bona fide belief that audit was not required constituted reasonable cause under section 273B, so penalty under section 271B could not be sustained.
Penalty for failure to obtain an audit report was deleted because the assessee had consistently treated sale of shops as giving rise to capital gains, and the characterisation of the activity as business or investment was a debatable issue. The Tribunal found that the transactions were identical to those in the preceding year, when penalty had already been cancelled, and there was no distinguishing feature to justify a different view. On these facts, the assessee's bona fide belief that audit was not required constituted reasonable cause under section 273B, so penalty under section 271B could not be sustained.
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