Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
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Penalty under section 270A was deleted because the assessee had made a deduction claim under section 80GGC, and the Assessing Officer had examined that claim; mere disallowance of the deduction did not, on these facts, establish under-reporting or misreporting. The Tribunal also held the penalty order unsustainable because it did not specify the applicable limb of section 270A or set out the particulars required to satisfy sub-section (9). As the statutory basis and necessary ingredients were not properly identified, the penalty could not be sustained.
Penalty under section 270A was deleted because the assessee had made a deduction claim under section 80GGC, and the Assessing Officer had examined that claim; mere disallowance of the deduction did not, on these facts, establish under-reporting or misreporting. The Tribunal also held the penalty order unsustainable because it did not specify the applicable limb of section 270A or set out the particulars required to satisfy sub-section (9). As the statutory basis and necessary ingredients were not properly identified, the penalty could not be sustained.
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